URGENT MOTION TO RELEASE THE ACCUSED Page 1 of 2

Republic of the Philippines

_____ Judicial Region
MUNICIPAL TRIAL COURT IN CITIES
Branch _____
____________ City

PEOPLE OF THE PHILIPPINES CRIMINAL CASE NO.

Plaintiff, ______________

-versus- -for-

__________________, VIOLATION OF BP BLG. 22

Accused.
X-------------------------------------x

URGENT MOTION TO RELEASE THE ACCUSED

ACCUSED, through the undersigned counsel, and unto this

Honorable Court, most respectfully avers that:

1. Accused in the instant case was released bail on 12 October

2018;1

2. Thereafter, the civil aspect of the instant case was referred to

Philippine Mediation Center, and an amicable settlement has
been reached by parties;

3. Said amicable settlement was confirmed by parties, thru

during the hearing conducted on 09 August 2019. In
consideration thereto, the Honorable Court ordered the
instant case ARCHIVED;2

4. The bond posted for the accused, was likewise, ordered

returned to the name of the payor in O.R. No. 8561804C
dated 12 October 2018;3

5. Surprisingly, by virtue of an Order of Arrest dated 08 February

2019,4 issued by this Honorable Court for the same case,
accused was mistakenly arrested and was placed on
detention5 at Police Station Nr. ___, today, 28 August
2019;

1
Annex A: Release Order dated 12 October 2018, with Cash Bond of PhP2,000.00, OR No. ___________
2
Annex B: Order dated 09 August 2019
3
Please see 2nd Paragraph of Annex B: Order dated 09 August 2019
4
Annex C: Order of Arrest dated 08 February 2019
5
Annex D: Certificate of Detention issued by ______________
 URGENT MOTION TO RELEASE THE ACCUSED Page 2 of 2

PRAYER

WHEREFORE, it is most respectfully prayed of the Honorable

Court to ISSUE AN ORDER FOR THE IMMEDIATE RELEASE OF THE
ACCUSED.

Other reliefs, just and equitable under the premises, are likewise
prayed for.

MOST RESPECTFULLY SUBMITTED, this 28 August 2019 at

________________________, Philippines.

_______________
Counsel for Accused
Roll No.
PTR No.
IBP No.
TIN
MCLE
Email address:

Office Address:

REQUEST FOR SUBMISSION

THE CLERK OF COURT

MCTC – Branch __
___________ City

Sir/ Madam:

Greetings! Please submit the foregoing URGENT MOTION for

the kind consideration and immediate approval of this Honorable Court
upon receipt hereof.

Counsel

Copy furnished: CITY PROSECUTOR’S OFFICE

______________ City