REPUBLIC OF THE PHILIPPINES

MUNICIPAL TRIAL COURT IN CITIES

City of Urdaneta
-oOo-

PEOPLE OF THE PHILIPPINES,

Plaintiff, CRIMINAL CASE NO.: U-27724
FOR: ESTAFA
-versus-

MARK JOHN B. REYNALDO

Accused.

x-------------------------------------------x

MOTION TO REDUCE BAIL

Accused, by way of special appearance solely for this purpose, respectfully
alleges that:
1. The accused has been charged of the estafa and that bail for their provisional
release has been set at EIGHTEEN THOUSAND PESOS (PH₱18,000);
2. The accused desires to post the required bail but due to financial constraints
considering that the his businesses had been experiencing severe businesses losses,
as well as, the fact that the accused had been charged in no less than 6 other cases,
all of which likewise require steep amounts of bail;
3. It would be advantageous to everyone if the accused be given temporary
liberty thereby allowing them to settle their affairs to be able to tend to his business
for the payment of whatever amount is due;
4. As such, accused appeals to the mercy and compassion of this Honorable
Court and respectfully requests that their bail be reduced to NINE THOUSAND
PESOS PH₱9,000;
5. This motion for reduction of bail is being filed without prejudice to any
other remedy which may be available to the accused and that the accused expressly
reserves the right to question the legality of the issuance of their warrant of arrest if
the circumstances would so warrant.
 WHEREFORE, in view of the foregoing, accused most respectfully prays
that his bail be reduced to NINE THOUSAND PESOS PH₱9,000 at a reduced
cash bond.
Other relief just and equitable are likewise prayed for.

Urdaneta City, Pangasinan, Philippines. 12 February 2020.

MARK JOHN B. REYNALDO

Accused

NOTICE OF HEARING

THE BRANCH CLERK OF COURT

Municipal Trial Court in Cities – Branch ___
Urdaneta City, Pangasinan

THE CITY PROSECUTOR’S OFFICE

Urdaneta City, Pangasinan

Greetings!

Please be informed that the accused hereby requests to submit the foregoing
motion for the consideration and approval of the Honorable Court immediately
upon the receipt by the Honorable Clerk of Court.

MARK JOHN B. REYNALDO

COPY FURNISHED:

PROSECUTOR ________________________
Office of the City Prosecutor
Urdaneta City