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Republic of the Philippines COURT ____th Judicial Region Branch ___ Davao City THE PEOPLE OF THE PHILIPPINES,

Complainant, -versusNAME OF ACCUSED Accused. X---------------------------X CRIMINAL CASE NO.________________ FOR: ESTAFA


UNTO THIS HONORABLE COURT, Accused, through counsel, most respectfully aver: 1. That Accused is presently detained at Police Station, ________ City, pending the hearing of this case, and that this case has been raffled to this sala; 2. That the Resolution of the Honorable Office of the City Prosecutor has fixed the bail of the accused at P20,000.00; 3. That the recommended bail for the offense of Estafa is P6,000.00, in accordance with the 2000 Bail Bond Guide of the Department of Justice National Prosecution Service; 4. That accused is not affluent in life, being a mere employee with minimum wage; 5. That the bail recommended is tantamount to the denial of bail. Where the right to bail exists, it should not be rendered nugatory by requiring a sum that is so excessive. 6. That accused is asking for the reduction of bail to P 10,000, which amount the accused can raise; 7. That accused is a good member of the community, and a resident of Davao City, and the probability of flight is nil;

8. That accused has not been previously convicted of any crime and have no pending case in any judicial or quasi-judicial body in the Philippines. 9. That accused will undertake to be present when this case is called in Court. PRAYER WHEREFORE, premises considered, it is most respectfully prayed that the Honorable Court will allow accused to post bail in the amount of P 10,000.00 for his provisional liberty during the pendency of this case. Davao City, Philippines, _____________.

ATTY. ____________________________ Counsel for the accused

THE CITY PROSECUTOR City Prosecution Office ________________________ ________________________


Greetings: Please submit the foregoing Motion for the consideration and approval of this Honorable Office on ________________ at __________oclock in the morning or as soon as this may be heard.

ATTY. ______________________