Republic of the Philippines

MUNICIPAL TRIAL COURT IN CITIES

11th Judicial Region
Province of Davao del Sur
City of Digos

THE PEOPLE OF THE PHILIPPINES, CRIM. CASE NO. _________

Plaintiff,
FOR: ESTAFA THRU FALSIFICATION
-versus- OF PUBLIC DOCUMENTS

_____________________,
Accused.
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EX-PARTE MOTION TO WITHDRAW BAIL BOND

IN FAVOR OF PRIVATE COMPLAINANT
COMES NOW, Private Complainant +++++++++++++++++++, by
himself, unto this Honorable Court, most respectfully moves for the
withdrawal of Accused’s bail bond, and respectfully states:

1. That in the Information filed in the above-entitled case, the

recommended bail bond for each of accused’s provisional liberty is
Twenty-Four Thousand Pesos (Php 24,000.00) Pesos or in the total bail
bond of the parties amounting to FORTY-EIGHT THOUSAND PESOD
(Php48,000.00);

2. That as per Decision dated December 12, 2018, this court approved
the compromise agreement duly signed by the private complainant
and the accused, agreeing among others that “The Accused will
pay the complainant the amount of One Hundred Fifty Thousand
Pesos (Php150,000.00) payable in the following amounts and dates
as follows, namely:
2.1. The Total bail bond of the parties amounting to FORTY-
EIGHT THOUSAND PESOD (Php48,000.00) upon the release
thereof;
xxx

3. In view of the Decision and compromise agreement, he thus appeals

to this Honorable Court for the withdrawal and release of the total
bail bond FORTY-EIGHT THOUSAND PESOD (Php48,000.00) previously
posted by the accuseds in his favor as payment on the compromise
agreement;

4. That Private Complainant filed this motion in view of the

urgent and pressing need and to exercise his rights as indicated in
their compromise agreement.

PRAYER

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 WHEREFORE, in view of the foregoing premises it is most respectfully
prayed that the motion be granted for the reason above-stated.
Such other reliefs as to this Honorable Court may appear as just
and equitable are otherwise being prayed for.

RESPECTFULLY SUBMITTED, this 21st day of May 2019, in Digos City,

Davao del Sur, Philippines.

By:

++++++++++++++++
Private Complainant

NOTICE OF SUBMISSION

THE CLERK OF COURT

MTCC
Digos City, Davao del Sur

Greetings!

Please take notice that the foregoing Motion to Withdraw Bail Bond
in favor of Private Complainant shall be submitted for the consideration
and approval of the Honorable Court without presence of counsel.

_____________________

Copy furnished:

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