Republic of the Philippines

REGIONAL TRIAL COURT

11th Judicial Region
BRANCH 3

THE PEOPLE OF THE PHILIPPINES CRIMINAL CASE NO.____

Plaintiffs, For: ________
-versus-

____________ ________________
Accused.
x------------------------------------------x

MOTION FOR EARLY RESOLUTION

COMES NOW, accused ________, by and through the

undersigned counsel, unto this Honorable Court, most respectfully
avers that:

1. A petition for bail and to fix the same had been filed for the
accused on November 11, 2015.

A copy of the petition for bail is hereto attached as Annex

“1” to form an integral part hereof;

2. In an order dated February 18, 2016, the prosecution was

given a period of thirty (30) days to submit a memorandum,
to comment on the subject Petition for Bail. However, the
prosecution failed to submit the memorandum within the
period provided;

Attached hereto as Annex “2” is a copy of an order dated

February 18, 2016 to form an integral part hereof;
 3. Thus, for failure of the prosecution to file comment within
the time provided, the Petition for Bail is submitted for
resolution to this court in an order dated February 13, 2018.

Attached hereto as Annex “3” is a copy of an order dated

February 13, 2018 to form an integral part hereof;

4. Almost three months had already passed and yet the

undersigned has not received a copy of the said resolution;

5. This motion is intended solely for the purpose alluded

thereto.

6. Thus, the undersigned is requesting for the early resolution

of the above-entitled case so as not to frustrate the ends of
justice.

PRAYER

WHEREFORE, forgoing premises considered, it is most

respectfully prayed of this Honorable Court that the instant
petition be resolved in the soonest possible time.

Other just and equitable reliefs are likewise prayed for.