Republic of the Philippines

REGIONAL TRIAL COURT

FIRST JUDICIAL REGION
Branch 7
Baguio City

PEOPLE OF THE PHILIPPINES,

Plaintiff,
CRIMINAL CASE NO.
144-A
-versus- For: RECKLESS IMPRUDENCE
RESULTING TO DAMAGE TO
PROPERTY
ANDREW VILLANIA
Accused.
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MOTION FOR REDUCTION OF BAILBOND

The accused, ANDREW VILLANIA, through the undersigned counsel in the above-
entitled case, and to this Honorable Court respectfully states that:

1. The accused, ANDREW VILLANIA, is charged for RECKLESS IMPRUDENCE

RESULTING IN DAMAGE TO PROPERTY now pending before this Honorable
Court with Criminal Case No. 144-A;

2. That the recommended bond for his provisional liberty is in the amount of FIFTY
THOUSAND PESOS (Php50,000.00);

3. That accused, considering that he is at this time suffering from financial constraints,
can only produce the amount of THIRTY THOUSAND PESOS (Php30,000.00)
CASH;

4. That accused needs his temporary liberty in order for him to gather all the necessary
evidence for his proper defense from this baseless accusation which he cannot do if
inside the prison;

5. That the accused together with his family is a permanent resident of this Province,
particularly at Cogcoga, Km. 3, La Trinidad, Benguet and therefore the possibility for
him to jump bail is too nil;

6. That the accused promise to attend all scheduled hearing in the above entitled case
and obeys all processes of this Honorable Court.

PRAYER

WHEREFORE, premises considered and in view of the foregoing, it is respectfully

prayed to the Honorable Court that the recommended bond of Php50,000.00 will be reduced to
Php30,000.00 CASH.

Other relief and remedies just and equitable under the premises are likewise prayed for.

Baguio City, for La Trinidad, Benguet, Philippines, this 17th day of January, 2014.
 JOANNE M. VENTIGAN
Attorney for the Accused
4F La Azotea Bldg., Session Road, Baguio City
Tel No.: (074)-442-3396
PTR No. 22222; 1/07/2012; Baguio City
IBP OR No: 7654321; 1/07/2012; Baguio City
Roll No.: 82112; 4/08/2004
Commission Serial No.: 74-NC-12 (R)
MCLE Compliance No.: IV-34458; 04/28/2012
TIN No: 802-112-107

NOTICE AND REQUEST

THE CLERK OF COURT

RTC Branch 7, Baguio City

Greetings!

Please submit the foregoing motion to the Honorable Court immediately upon receipt
thereof for its consideration and approval without further arguments.

ATTY. JO-ANNE M.VENTIGAN

Copy Furnished:
Office of the City Prosecutor
Baguio City, Philippines