Republic of the Philippines

__________ JUDICIAL REGION

REGIONAL TRIAL COURT
Branch ______
_________________________

REPUBLIC OF THE PHILIPPINES

Plaintiff,
CRIM. CASE NO. ______________
-versus-

______________________________,
Accused.
x---------------------------x

MOTION FOR RELEASE

COMES NOW _________________, by his undersigned counsel, unto this

Honorable Court, respectfully avers that;

1. _____________ was convicted by this Honorable Court of the violation of

Section 12 of Article 2 of RA 9165 and was sentenced to serve a term of
imprisonment of Six (6) months and One (1) day;

2. He already served his sentence because he was detained at

_______________________since ____________________ and was granted
Good Conduct Time Allowance totaling _________ days. The Certificate of
Detention is hereto attached as Annex “A” and the Certificate of Good
Conduct Time Allowance is likewise attached as Annex “B”;

3. He already undergone drug dependency examination and was found

negative. The result of the Drug Dependency Examination is hereto attached
as Annex “C”;

4. He already paid the fine of Ten Thousand Pesos imposed by the Honorable
Court. The of the receipt of the fine is hereto attached as Annex “D”;

WHEREFORE, premises considered, it is respectfully prayed that this

Honorable Court orders the release of _______________ from detention.

Other relief and remedies, just and equitable under the premises are likewise
prayed for.

Respectfully submitted, _________________, ___________, 2019.

COUNSEL