Republic of the Philippines

METROPOLITAN TRIAL COURT

National Capital Judicial Region
Branch 150, Malabon City

PEOPLE OF THE PHILIPPINES,

-versus- Criminal Case No. xxxxxxx

For: Violation of BP No. 22

LUCKY GONZAGA,
x------------------------------------------x

MOTION TO ALLOW ACCUSED TO POST BAIL

with MOTION TO REDUCE

Accused, LUCKY GONZAGA, through the assistance of the

undersigned counsel, by way of special appearance solely for this
purpose, unto this Honorable Court, most respectfully avers:

1. That the accused has been charged with Violation of Batas

Pambansa Blg. 22 and the recommended bail for her provisional
release has been set at Php. 30,000.00.

2. That the accused is the sole breadwinner of her family, her parents
both retired, she is into business of selling overrun clothes and the
sole supporter of her parents including her sibling who are all
dependent to her for support.

3. Due to financial constraint, she could not afford to post bail based
on the recommended bail for the above reason. As a matter of fact,
accused parents are both currently taking maintenance for aid in
their health and it is the accused that is solely providing for their
medical needs.

4. That the accused intends to post bail for her provisional liberty, to
continue with her small business, that is the only means for her to
support her ailing parents and dependents siblings.

5. That herein accused undertakes to attend all the scheduled

hearing of the Honorable Court and will submit his full cooperation
thereto for the immediate and speedy disposition of the above-cited
case.

6. This motion is not intended to disturb the proceeding but solely for
the above stated reason.

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed

of this Honorable Court that herein accused be allowed to post bail and
the recommended bail in the amount of THIRTY THOUSAND PESOS
(PHP. 30,000.00) be reduced to at least half, to be posted by way of
cash, for the accused to avail of her constitutional right to bail.

Other reliefs just and equitable are likewise prayed for.

XXXX City, 29 March 2018.

Atty. xxxxxx
Counsel for the Accused
IBP Membership No.
Roll of Attorney No.
PTR. No.

NOTICE OF HEARING

Office of the City Prosecutor

Prosecutor’s Hall, Justice Compound
Malabon City

The Branch Clerk of Court

Metropolitan Trial Court
Branch 150, Malabon City

Greetings:

Please submit the same for the kind consideration and approval of
the Honorable Court immediately upon receipt hereof or at anytime
convenient thereto.

xxxx

COPY FURNISHED:

Office of the City Prosecutor