Republic of the Philippines

REGIONAL TRIAL COURT

Second Judicial Region
Branch 21
Santiago City

PEOPLE OF THE PHILIPPINES

Plaintiff,
-versus- Criminal Case No. 21-8860-
FC
For: Violation of RA 9262
FEDERICO PAMPUAN
Accused.
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MOTION FOR RECONSIDERATION

COMES NOW, the undersigned movant and unto this Honorable

Court, respectfully avers:

1. That the herein movant is the Area Manager of Alpha Insurance &
Surety Company, Inc. Region 2.
2. That on July 10, 2019, the undersigned received a copy of the Order
dated May 24, 2019, stating among others, that the surety bond
posted by the Alpha Insurance and Surety Co., Inc., for the
provisional liberty of the accused was ordered cancelled and
confiscated in favor of the government and that a warrant of arrest
be issued against the herein accused;
3. That the said Order was received only when one of the
undersigned’s staffs in the name of Maricel Servilla personally went
to the Regional Trial Court Branch 21, Santiago City, Isabela in
order to acquire clearance for the surety company;
4. That prior to the receipt of the May 24, 2019 Order, the undersigned
has never been furnished with copies of Orders from the Honorable
Court as it was confirmed that it was the Alpha Insurance and Surety
Co., Inc, Quezon City, Manila which posted the surety bond of the
accused;
5. That in view of the May 24, 2019 Order, the undersigned hereby
confirms the death of accused Federico Pampuan as evidenced by
his Certificate of Death issued by the Philippine Statistics Authority,
a copy of which is hereto attached as Annex “A”;
6. Thus, movant respectfully prays unto this Honorable Court that the
Order dated May 24, 2019 be reconsidered and the herein movant
be released from any liability arising therefrom.
 WHEREFORE, premises considered, it is most respectfully prayed
unto this Honorable Court that the Court Order dated May 24, 2019 be
reconsidered and the herein movant be released from any liability arising
therefrom.
Cauayan City, Isabela for Santiago City, Isabela. July 10, 2019.

ALPHA INSURANCE & SURETY COMPANY,

INC.,
By:
MYRNA FELY D. RESURRECCION
Bondsman

THE CLERK OF COURT

Regional Trial Court
Branch 21
Santiago City, Isabela

Greetings!

Kindly submit the foregoing motion to the Honorable Court for its kind
consideration and approval immediately upon receipt hereof.

MYRNA FELY D. RESURRECCION

Copy furnished:

OFFICE OF THE CITY PROSECUTOR

Santiago City, Isabela