Republic of the Philippines

National Capital Judicial Region

MUNICIPAL TRIAL COURT IN CITIES
City of Meycauayan
Province of Bulacan
Branch 1

PEOPLE OF THE PHILIPPINES,

Complainant,

-versus- Criminal Case No. XX-123

For: Theft
BOY BASURA and
BOY KATKONG,
Accused.
x ------------------------------------ x

EX PARTE MOTION TO RELEASE BAIL

ACCUSED, BOY BASURA, through the undersigned counsel and
unto this Honorable Court, most respectfully states that:

1. He posted bail for his provisional liberty in the above-entitled

case as evidenced by Official Receipt No. 123456, dated 01 March 2018,
a copy of which is hereto attached as Annex “A” and made an integral
part hereof.

2. In the Judgment of the Honorable Court promulgated on 10

January 2020, herein Accused was convicted of the charge against him.

3. At present, Accused is applying for probation with the Honorable

Court, having all the qualifications and none of the disqualifications to
avail of the benefits of the Probation Law.

4. Accused would like to request for the release of the bail bond that
he posted, so that it may be returned to the person from whom the said
amount was borrowed.

WHEREFORE, in view of the foregoing, accused most respectfully

prays that his cash bail bond be released.

Other reliefs just and equitable in the premises are likewise

prayed for.
 Respectfully submitted.

Malolos City for the City of Meycauayan, 20 January 2020.

By:

JENNIFER DELA CRUZ

Roll No. 666666
PTR No. 12345/01-07-202O/Bulacan
IBP OR No. 12345/01-07-2020/Bulacan
MCLE Compliance No. VI-0000001, 01 February 2018

NOTICE OF HEARING

THE BRANCH CLERK OF COURT

MTC - Branch 1
City of Meycauayan

Greetings!

Being a non-litigated motion, please submit the foregoing motion

for consideration and approval of this Honorable Court immediately
upon receipt hereof.

JENNIFER DELA CRUZ

Copy furnished:

OFFICE OF THE CITY PROSECUTOR

City of Meycauayan, Bulacan
Ground Floor, Meycauayan City Hall
Brgy. Camalig, City of Meycauayan, Bulacan