REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

BRANCH 3
BAGUIO CITY
PEOPLE OF THE PHILIPPINES
Plaintiff,
- versus 39206-R

CRIMINAL CASE Nos.

36603-R
For: Estafa
CONCEPCION NIPAHOY,
Accused.
x--------------------------------------x
URGENT MOTION to REDUCE BAIL
WITH ALL DUE RESPECT.
The accused through the undersigned counsel state
that:
1. That the accused has been charged with Estafa in both
of these cases and that the bail for her provisional
release for Criminal Case No. 39206-R has been set at
P_____________ , while for Criminal Case No. 36603-R
the bail for her provisional release is set at Php.
______________;
2. That the accused is a poor fellow of very limited means
such that it is impossible for her to pay the full amount
of her bond and was only able to raise the total amount
of Php 200,000.00, an amount borrowed from friends
and relatives and is therefore constrained to request for
a reduction of the amount of bail;
3. That it would be advantageous to everyone if she be
given temporary liberty thereby allowing him to
continue with her gainful employment and as head of
the family with 3 dependents;

4. The accused have valid defense and the possibility of

the accused escaping and becoming fugitives from
justice is very remote.
5. As such, accused appeals to the mercy and compassion
of this Honorable Court and respectfully requests that
her bail for Criminal Case No. 39206-R be reduced to
P_____________, while for Criminal Case No. 36603-R the
bail for her provisional release be reduced to
P_____________.
6. That this motion for reduction of bail is being filed
without prejudice to any other remedy which may be
available to the accused
WHEREFORE, accused respectfully prays that his bail be
reduced to P_____________.
Other
reliefs
just
and
equitable
circumstances are likewise prayed for.
Baguio City,October 24, 2016.

under

DONAAL,ARCIAGA and Partners Law Office

Counsel for Accused
U/G Baden Powell Hotel
26 GOv. Pack Rd., Baguio City
By:
CHRISTOPHER D. DONAAL
Privilege Tax Receipt No. 2516453; 03 February 2016
IBP Lifetime No. 96875; Mountain Province Chapter
Roll No. 52587; 12 May 2006
MCLE Compliance No. IV-0020927; 20 June 2013
Notice of Hearing and copy furnish:
The Honorable Public Prosecutor

the