SAINT LOUIS UNIVERSITY SCHOOL OF LAW MOOT COURT BAGUIO CITY

PEOPLE OF THE PHILIPPINES Plaintiff, -versus-

CRIM. CASE NO.__1023 - R

FOR: VIOLATION OF ARTICLE 319, PAR. 1 OF THE REVISED PENAL CODE

SALVADOR DS CLAVERIA Accused. X---------------------------------------X

MOTION TO REDUCE BAIL

Accused, through counsel, by way of a special appearance solely for this purpose, respectfully alleges:

1. That the accused has been charged with violation of Article 319, par. 1 of the Revised Penal Code and that the bail for his provisional release has been set at P_____________; 2. That the accused is an ordinary citizen working very hard just to meet his needs and his familys such that it is impossible for him to pay the full amount of his bond and is therefore constrained to request for a reduction of the amount of bail;

3. That it would be advantageous to everyone if he be given temporary liberty thereby allowing him to continue with his gainful employment and as head of the family with three (3) dependents; 4. As such, accused appeals to the mercy and compassion of this Honorable Court and respectfully requests that his bail be reduced to P 10,000. 5. That this motion for reduction of bail is being filed without prejudice to any other remedy which may be available to the accused and that the accused expressly reserves the right to question the legality of the issuance of the search warrant or his warrantless arrest if the circumstances would so warrant.

WHEREFORE, accused respectfully prays that his bail be reduced to P_____________. Other relief just and equitable are likewise prayed for. November 26, 2011, Baguio City Philippines.

MYKEDOX KNOEL CUCHAPIN Counsel for the Accused Roll No. IBP No. PTR No. Address: MCLE Compliance No.

cc: / OFFICE OF THE CITY PROSECUTOR Justice Hall, Baguio City Philippines HERMINIGILDO S. PALAYON #41 Bayan Park Village, Aurorra Hill, Baguio City

Personal Service. ___________ Date: _____________ Personal Service. ___________ Date: _____________