Republic of the Philippines

REGIONAL TRIAL COURT

FIRST JUDICIAL REGION
Branch 7
Baguio City
PEOPLE OF THE PHILIPPINES,
Plaintiff,
Criminal Case No. 144-A
For: Reckless Imprudence
Resulting in Damage
to Property

v.
CHLOE JACOB,
Accused.
x----------------------------------------x

MOTION FOR REDUCTION OF BAILBOND

The accused, CHLOE JACOB, through the undersigned counsel in the
above-entitled case, and to this Honorable Court respectfully states that:
1. The accused, CHLOE JACOB, is charged for RECKLESS
IMPRUDENCE RESULTING IN DAMAGE TO PROPERTY now
pending before this Honorable Court with Criminal Case No. 144-A;
2. That the recommended bond for her provisional liberty is in the amount
of FIFTY THOUSAND PESOS (Php50,000.00);
3. That accused, considering that she is at this time suffering from financial
constraints, can only produce the amount of THIRTY THOUSAND
PESOS (Php30,000.00) CASH;
4. That accused needs her temporary liberty in order for her to gather all the
necessary evidence for her proper defense from this baseless accusation
which she cannot do if inside the prison;
5. That the accused together with her family is a permanent resident of this
City, particularly at 23 Salud Mitra, Baguio City, and therefore the
possibility for her to jump bail is too nil;

6. That the accused promise to attend all scheduled hearing in the above
entitled case and obeys all processes of this Honorable Court.
PRAYER
WHEREFORE, premises considered and in view of the foregoing, it is
respectfully prayed to the Honorable Court that the recommended bond of Php
50,000.00 will be reduced to Php30,000.00 CASH.
Other relief and remedies just and equitable under the premises are likewise
prayed for.
Baguio City, Philippines, this 13th day of August 2014.

ATTY. LAWRENCE PATRICK P. ESTILLORE

Counsel for the accused
285 Abanoa St., Baguio City
PTR No. 123/Baguio City/12-31-14
Roll of Atty. No. 64935
IBP Lifetime Membership No. 3319
MCLE Compliance No 8467

NOTICE FOR and REQUEST OF HEARING

PROOF OF SERVICE (Office of the Prosecutor)