REPUBLIC OF THE PHILIPPINES

FOURTH JUDICIAL REGION

FAMILY COURT – BRANCH 1
Bulwagan ng Katurangan
Pallocan West, Batangas City

THE PEOPLE OF THE PHILIPPINES,

Plaintiff,
Criminal Case No. 20-26990
- versus –
For: Lascivious Conduct
JOHN ISAAC NASE y MACALALAD,
Accused.
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MOTION FOR REDUCTION OF BAIL

COMES NOW, accused JOHN ISAAC NASE y MACALALAD, through the

undersigned BONDSWOMAN, his mother and unto this Honorable Court, most respectfully
states:

That the accused is presently detained at the Batangas City Police Station, Batangas City;

That the bail recommended by the Provincial Prosecutor for her provisional liberty is
Php 180,000.00;

That accused is presently without adequate means by which to raise the entire amount of
Php 180,000.00 recommended by the City Prosecutor as bail;

That in view thereof, it is prayed that the recommended bail be reduced from Php
180,000.00 to Php 90,000.00 which amount she will be able to produce through the help of some
relatives;

That should this Motion be granted, the accused undertakes that he will obey all the
orders of the Court and be present in all stages of the proceedings;

Premises considered, it is most respectfully prayed of this Honorable Court that an Order
be issued allowing the reduction of bail from Php 180,000.00 to Php 90,000.00.

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

Batangas City, 25 September 2020.

IRMA M. NASE
Mother of the Accused / Bondswoman

ATTY. DEXTER JONAS M. LUMANGLAS

The Branch Clerk of Court
Branch 1, Family Court, Batangas City

GREETINGS:

Please submit the foregoing motion to the Honorable Court immediately upon receipt
hereof.

IRMA M. NASE
Mother of the Accused / Bondswoman

Copy furnished:

The City Prosecutor

Batangas City