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Republic of the Philippines

REGIONAL TRIAL COURT OF NEGROS ORIENTAL


7th Judicial Region
RTC Branch ___
Dumaguete City

PEOPLE OF THE PHILIPPINES, FOR: Viol. RA 10591


Plaintiff

-versus-

HERCULANO INOFERIO y
TENIQUIS alias “ALLAN”
Brgy. Magsuhot, Bacong, Negros
Oriental
Respondent.

MOTION TO REDUCE BAIL

Complainant, through counsel, by way of a special appearance solely


for this purpose, respectfully alleges:

1. That the complainant is the registered owner of a Honda motorcycle,


bearing Engine No. HC08E-5003734, Chasis No. KTL10-05Z-00374,
covered by Certificate of Registration No. 3256830-3;

2. That the said motorcycle was carnapped last July 7, 2019 somewhere
at Boloc-boloc, Sibulan, Negros Oriental;

3. That my said motorcycle was however recovered and is now in


custody of Hifghway Patrol Group, Dumaguete City;

4. That as the investigation is on progress, it is my desire to make use of


my said motorcycle;

5. Considering that the accused is still presumed innocent until proven


guilty, as guaranteed by our Constitution and embodied in the Rules

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of Court, we seek the indulgence of this Honorable Court to allow the
accused to post bond in a reduced amount in order for him to enjoy
his temporary liberty outside the Provincial Jail of Negros Oreintal.

PRAYER

WHEREFORE, premises considered and in the interest of substantial


justice, accused pray that he be allowed to post cash bond in the amount of
Sixty Thousand Pesos (Php60,000.00).

Other relief and remedies as may be deemed just and equitable under
the premises are likewise prayed for.

Dumaguete City, Negros Oriental, Philippines, 19th day of November


2019.

ATTY. AL-ZHAIN I. SADJAIL


Counsel for the Respondent
Roll No. 66734
PTR. No. 2112785- 01/04/2019
IBP No.061006 - 12/20/2018
MCLE No. VI-0008277 until 4/14/2022
2nd floor Lupega Building,
Dr. V. Locsin Street, Dumaguete City,
Negros Oriental, Philippines

Copy furnished:

Jo ann Marie A. Munoz-Abada


Prosecutor II
Provincial Prosecutor’s Office

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