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Sample Motion Reduce Bail

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Republic of the Philippines

METROPOLITAN TRIAL COURT


National Capital Judicial Region
Caloocan City
Branch ______

PEOPLE OF THE PHILIPPINES


Plaintiff,
CRIM. CASE NO. 1234

RECKLESS IMPRUDENCE
RESULTING IN HOMICIDE
-versus-

xxxxxxxxxxxxxxxxxxxxx
Accused.
X---------------------------------------X

MOTION TO REDUCE BAIL

ACCUSED, by himself, most respectfully moves to reduce his bail


and avers that:

1. On July 22, 2019, an information was filed charging the


accused of the crime of reckless imprudence resulting in
homicide and the bail recommended for his temporary
release was set at P30,000.00.

2. He is temporarily detained at Caloocan City Jail.

3. The accused is an ordinary citizen who is earning his


income from driving public utility jeepney. His four
children are depending on him for support. He has no
other source of income as his wife is plain housewife.

4. Under Section 4 of A.M. No. 12-11-2-SC 1, if the accused


does not have the financial ability to post the amount of
bail that the court initially fixed, he may move for its
reduction, submitting for that purpose such documents or
affidavit as may warrant the reduction he seeks.

5. Furthermore, the Supreme Court Committee for


Decongestion of Provincial City and Municipal Jails has
recommended for the adoption of guidelines for

1
Guidelines for Decongesting Holding Jails by Enforcing the Rights of the Accused Persons to Bail and
Speedy Trial
decongesting holding jails by enforcing the rights of
accused persons to bail and to speedy trial2.

6. Considering that the accused is still presumed innocent


until proven guilty, as guaranteed by our Constitution and
embodied in the Rules of Court, we seek the indulgence
of this Honorable Court to allow the accused to post bond
in a reduced amount in order to allow the accused to post
bond in a reduced amount in order for him to continue to
support the finances of his family and for him to enjoy his
temporary liberty outside the congested Caloocan City
jail.

PRAYER

WHEREFORE, it is most respectfully prayed to this Honorable Court


to reduce the bail from P30,000.00 to P15, 000.00.

Other reliefs just and equitable are likewise prayed.

July 26, 2019, Caloocan City

xxxxxxxxxxxxxxxxxxx
Accused

NOTICE OF HEARING

THE CLERK OF COURT


Metropolitan Trial Court
Branch ___

Madam:

Please set the foregoing motion for the consideration and approval of
the Honorable Court.

Thank you.

xxxxxxxxxxxxxx
Accused

2
Ibid

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