Republic of the Philippines

Second Judicial Region

MUNICIPAL TRIAL COURT IN CITIES
Branch 01
Tuguegarao City, Cagayan

PEOPLE OF THE PHILIPPINES,

CRIMINAL CASE NO. 30723
-versus-
For:
ALFREDO ROMMEL CASIBANG
REYES, II, ET. AL, Slight Physical Injuries
Accused.
x-----------------------------------------x

MOTION TO FIX BAIL

TO THIS HONORABLE COURT, Accused, through the undersigned

counsel, most respectfully states that:

1. A warrant of arrest was issued by this Honorable Court directing the

immediate arrest of ACCUSED Edwin Balauag Gutierrez for his failure
to attend the last hearing;

2. He failed to appear because he never received notices and court

processes emanating from this Honorable Court;

3. The warrant of arrest issued by the Court did not fix the amount of
recommended bail to be posted for the temporary liberty of accused
Edwin Balauag Gutierrez;

4. Accused most respectfully prays that the amount of the bail bond for
his temporary liberty be fixed by the Honorable Court;

5. Accused is willing to pay the amount that the court shall fix for his
temporary liberty; and

6. Accused hereby manifests that he has no intentions to flee or do acts

which will frustrate the ends of justice. Accused likewise undertakes
to appear before this Honorable Court whenever required.

PRAYER

PREMISES CONSIDERED, it is most respectfully prayed of this

Honorable Court to fix the amount of bail for Accused provisional liberty.

Such other reliefs which are just and equitable under the premises
are likewise prayed for.

Tuguegarao City, Cagayan. February 2, 2018.

 JIMENEZ PAUIG BAUTISTA AND LABUGUEN
LAW OFFICE
Counsel for the Accused
nd
2 Floor Archbishop’s Centennial Building
Blumentritt St. corner Arellano St.,
Tuguegarao City, Cagayan.
Tel. no. (078)-846-7891
E-mail:jbclaw@yahoo.com
BY:

ERIC O. LABUGUEN, CPA

Roll No.: 59081
IBP Lifetime OR No. 1068629 – 06/15/17, Cagayan
PTR OR No.: CGYN 7821277, 01/08/18, Cagayan
MCLE Compliance No. V -0014490 issued 04/15/ 2016
Valid Until 04/ 14/2019
 NOTICE OF HEARING

CITY PROSECUTORS OFFICE

Tuguegarao City, Cagayan

TO THE BRANCH CLERK OF COURT

Municipal Trial Court in Cities
Branch 01
Tuguegarao City, Cagayan

Greetings!

Please submit the foregoing motion upon receipt hereof for the
perusal by and consideration and approval of the Honorable Court.
Please calendar the same on February 02, 2018 at 1:30 PM. Thank you.

ERIC O. LABUGUEN

PROOF OF SERVICE

Copy furnished:

CITY PROSECUTORS OFFICE

Tuguegarao City, Cagayan

TO THE BRANCH CLERK OF COURT

Municipal Trial Court in Cities
Branch 01
Tuguegarao City, Cagayan

EXPLANATION

Copies of the motion are served to the respective parties through

registered mail due to distance and lack of manpower of the
undersigned. (Please disregard if personally served).

ERIC O. LABUGUEN