REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

11TH JUDICIAL REGION
BRANCH 34
PANABO CITY

THE PEOPLE OF THE X------------------------------------x

PHILIPPINES,

-versus- CRIMINAL CASE NO. 64-2005

JULIO ZABATE, R.A. 6539

et. al.,
Accused.

EX PARTE MOTION TO
RELEASE (PROPERTY) BAILBOND
WITH AD CAUTELAM MOTION FOR RECONSIDERATION
(of the order dated February 2, 2015)

Petitioner JULIO ZABATE, through the undersigned public attorney,

respectfully submits this motion, stating THAT;

1. This Honorable Court, in its order dated February 2, 2015

promulgated a decision on the above-mentioned case;

2. This Honorable Court, found in the said Order that due to the
continued non-appearance of the above-named accused the
property bond covered by OCT No. P-11728 was ordered forfeited in
favor of the State;

3. As per attached Certificate of Detention, however, the above-

named accused has been under police custody since July 4, 2017.

4. The owner of the said property bond forfeited, is an elderly, who

now comes to the mercy of this Honorable Court for her to be able
to recover the property forfeited given that Julio Zabate is now
already in custody.

5. The property bond posted is under the charge of this Honorable

Court.

WHEREFORE, based on the foregoing, petitioner respectfully prays

that an order be issued for the release of the PROPERTY BOND covered by
OCT No. P-11728.

Other reliefs just and equitable under the premises are equally prayed
for.
RESPECTFULLY SUBMITTED.
 Panabo City, Davao del Norte, Philippines. 27th of October, 2017.

JOAHNA PAULA Q. DOMINGO

Public Attorney I
PTR No. 9195872; 07/04/2017
IBP O.R No. 006046
Roll No. 67043
Admitted to Bar May 2017

NOTICE OF HEARING/SUBMISSION

The Branch Clerk of Court

RTC Branch 34

Pros. Rocarma Nuesca

Please take notice that the undersigned counsel submitted the foregoing for
the consideration of this Honorable Court on October 27, 2017 without prejudice to
further appearance and oral arguments which may be required by the court of the
undersigned counsel.

JOAHNA PAULA Q. DOMINGO

Copy furnished:

PANABO CITY PROSECUTIONS OFFICE

Panabo City, Davao del Norte