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Republic of the Philippines

MUNICIPAL TRIAL COURT IN CITIES


Third Judicial Region
_______________ City
Branch 0001

PEOPLE OF THE PHILIPPINES,


Plaintiff,

-versus- Criminal Case No. 123456


For: Grave Coercion

JUAN DELA CRUZ,


Accused.
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EX PARTE MOTION TO RELEASE BAIL

Accused, through the undersigned counsel, unto this Honorable


Court, respectfully states:

1. That the accused posted bail for his provisional liberty in the above-
entitled case as evidenced by Official Receipt No. 3268157B dated
August 20, 2010 A copy of which is hereto attached as Annex “A”;

2. That in the Decision of the Honorable Court dated on August 17, 2018,
the accused is hereby CONVICTED of the crime of Grave Coercion and
hereby sentenced to suffer an indeterminate prison term of Four (4)
months and One (1) day of arresto mayor to Two (2) years, Four (4)
months and One (1) day of prision correccional. Accused was further
ordered to pay a fine of Three Thousand (Php3,000.00) Pesos, with
subsidiary imprisonment in case of insolvency;

3. That a Petition for Probation dated November 7, 2018 was filed by the
accused and was granted by this Honorable Court;

4.

5. However, the said decision failed to provide the release of the bail bond
posted by the accused.

WHEREFORE, in view of the foregoing, accused most respectfully prays


that his cash bail bond be released.

Other just and equitable reliefs are likewise prayed for.

Respectfully submitted.

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