REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

METROPOLITAN TRIAL COURT
Branch 55, Malabon City

PEOPLE OF THE PHILIPPINES,

-versus- CRIMINAL CASE NOS. JLOO-21398-21400

For: Violation of City Ordinance No. 07-
2005(Half Naked)
Alarms and Scandal
Grave Threat
JANO CRUZ y AGUILAR
Accused.
x - - - - - - - - - - - - - - - - - - - - - - - -x
OMNIBUS MOTION

COMES NOW, accused JANO CRUZ y AGUILAR , by himself, unto this Honorable
Court, most respectfully manifests that:

1. The accused was arrested on March 25, 2015. He is presently detained at Malabon City
PNP Detention;
2. Accused stands charged of Alarms and Scandal as well as Grave Threat. For each of
these, the bail recommended is at Two Thousand Pesos (Php2,000.00). Accused
however, most respectfully manifests that he is unable to put up the total amount of Four
Thousand Pesos (Php4,000.00) for his provisional liberty as he has lost his job and will
only come up with the money for his bail from family and relatives. Thus, he implores
that the Honorable Court reduce the amount of his bail for the abovementioned cases at
One Thousand Pesos each (Php 1,000.00), cash bond.
3. Meanwhile, accused is also indicted for the violation of Malabon City Ordinance No.
07-2005 (Half Naked) where there is no bail fixed/recommended. For this reason,
accused likewise moves that the Honorable Court fix the bail for the Half-Naked case
filed against him in order for him to enjoy provisional liberty during the pendency of the
trial of the instant cases;
4. In view thereof, the accused prays for the compassion of the Honorable Court that the
bail for his provisional liberty for Alarms and Scandal and Grave Threat be reduced and
that the Honorable Court fix the bail for his Half-Naked case to allow him to enjoy
provisional liberty while the instant cases are pending.

WHEREFORE, IN THE LIGHT OF THE FOREGOING, it is most respectfully

prayed of this Honorable Court that the bail for his provisional liberty for Alarms and
Scandal and Grave Threat be reduced and that the Honorable Court fix the bail for his Half-
Naked case to allow him to enjoy provisional liberty while the instant cases are pending.

Malabon City, Metro Manila, 08 April 2015.

JANO CRUZ y AGUILAR

Accused

NOTICE OF HEARING

Officer in Charge
MTC-Branch 55
Malabon City, M.M.

G R E E T I N G S! Kindly submit the foregoing Motion for the consideration and

approval of this Honorable Court or soon thereafter as accused may be heard.

JANO CRUZ y AGUILAR

Accused
Copy Furnished:
Prosecutor’s Office Malabon City, M.M.