RA 10591/ VIOL OF OMNIBUS FELICIANO BIYANG LADYONG, ELECTION CODE Accused. x----------------------------------------------x URGENT MOTION TO LIFT WARRANT OF ARREST WITH PRAYER FOR THE REINSTATEMENT OF THE BAILBOND Accused and his bodsman Sergio W. Dinulong, by themselves, unto this Honorable Court, respectfully state:
1. That an order for the issuance of a bench warrant of arrest
against accused had been issued in open court on September 16, 2019 in the afternoon for he and his bodsman failed to comply with the Order of the Honorable Court dated April 25, 2019;
2. It is respectfully submitted that the failure of the accused to be
present on said date was due to sickness. Herein accused had been suffering from hypertension/high blood pressure three (3) days prior to and continued for another two (2) days after the scheduled hearing of his case, which practically prevented him from attending his case. He went for consultation/check-up at Bulanao Community Clinic and Clinical Laboratory as evidenced by the hereto attached Medical Certificate issued by Dra. Cynthia C. Dawey;
3. That sickness is a tempest that besets any person at any given
time;
4. That accused had no least intention to shun away from his case and did not mean to belittle the proceedings of the case but mainly for the reason afore-stated; and
5. Thus, herein accused begs the kind indulgence of the Honorable
Court, that the Warrant of Arrest against him be lifted and/or recalled. PRAYER WHEREFORE, premises considered, in the interest of substantial justice, it is respectfully prayed that this Motion be favorably considered and LIFT the Warrant of Arrest against accused and REINSTATE the bail bond previously posted by the Accused for his provisional liberty.
Other reliefs just and equitable under the premises are likewise prayed for.
RESPECTFULLY SUBMITTED.
By:
REQUEST
The Branch Clerk of Court
Branch 25, Regional Trial Court Tabuk City, Kalinga
G R E E T I N G S:
Please submit the foregoing MOTION immediately for the kind
approval and consideration of the Honorable Court immediately upon receipt hereof.
