REPUBLIC OF THE PHILIPPINES

MUNICIPAL TRIAL COURT

BRANCH 1
GUAGUA, PAMPANGA

THE PEOPLE OF THE PHILIPPINES,

CRIMINAL CASE NO: XXXXXXXXXXX
for: ESTAFA Through falsification of public
document under article 315 1(b) in relation
to Article 171 and 172 if the Revised Penal
Code as amended by RA 4
no. 10951
-versus-

XXXXXXXXXXXXXXX
Accused,

Motion to Release Cash Bail Bond

DEFENDANT, unto this Honorable Court, most respectfully moves for the
release of his Bail Bond in the above-captioned case, alleging as follows:
1. That the herein Defendant has posted Cash Bail Bond for his provisional
liberty during the pendency of the above-captioned case, as evidenced by
Official Receipt No. _____________, dated _____________, a copy of which
is hereto attached as Annex "A" and made an integral part hereof;
2. That November 26, 2018, the Honorable Court dismissed the herein case
for lack of jurisidiction based on Venue.
3. However, the said resolution failed to provide for the release of the Bail
Bond posted by the herein accused.
PRAYER
WHEREFORE, in view of the foregoing, Defendant most respectfully prays
that his Cash Bail Bond be released.
Other relief just and equitable are likewise prayed for.
_____________, Philippines, __Date__.

PUBLIC ATTORNEY’S OFFICE

Guagua District Office
Counsel for the Accused
Deelish (formerly Plate & Platters)
Olongapo-Gapan Road
 San Matias, Guagua, Pampanga

By: ATTY. XXXXXXXXX

Public Attorney I
IBP Lifetime Member No. - XXXXX
Pampanga Chapter
Roll of Attorney’s No. XXXXXX

Copy furnished:
XXXXXXXXXXXX
Office of the Provincial Prosecutor
City of San Fernando Pampanga

Guagua Postal Office

3rd Floor Andres P. GosecoHall
Plaza Burgos, Guagua, Pampanga
Registry Receipt No. ____________

XXXXXXXXXXXXX
Suite 507 FMSG building
No. 9 Balete Drive, corner 3rd Street
New Manila, Quezon City

Guagua Postal Office

3rd Floor Andres P. GosecoHall
Plaza Burgos, Guagua, Pampanga
Registry Receipt No. ____________

NOTICE OF HEARING
The Branch Clerk of Court
Municipal Trial Court, Branch 1
Guagua, Pampanga

GREETINGS:

Please take notice that the foregoing Motion to Release Cash Bail Bond will
be submitted for the consideration and approval of the Honourable Court
immediately upon receipt hereof.
 XXXXXXXXXXXXX
Public Attorney I

EXPLANATION

The foregoing Motion to Release Cash Bail Bond is being served through
registered mail because personal service is not practicable due to distance and
time constraints.

XXXXXXXXXXXXXXXX
Public Attorney I