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REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION


METROPOLITAN TRIAL COURT
QUEZON CITY
BRANCH 43
PEOPLE OF THE
PHILIPPINES
Plai
ntif,

CRIM CASE NOS. 08567


For: Theft

-versusCHRISTOPHER PUERTAS
Y FAUTAGANA
Accused.
x-----------------------------------------x
MOTION TO RELEASE CASH BOND
Movant, CHRISTOPHER PUERTAS y FAUTAGANA,
unto this Honorable Court respectfully states that:
1. On 10 March 2015, this Honorable Court issued an
Order provisionally dismissing the instant case for
failure of private complainant to apper despite due
notice. A copy of the Order is herein attached as
Annex 1
2. To obtain the temporary liberty herein accused
CHRISTOPHER
PUERTAS
y
FAUTAGANA
pending the hearing of the instant case, MOVANT
posted a cash bond in the total amount of EIGHT
THOUSAND PESOS (P8,000.00) for the abovementioned case. A copy of the receipt is attached
herein as Annex 2.
3. In view of the said DISMISSAL of the case, it is
hereby moved that the cash bond posted by the
MOVANT be released to him.

PRAYER
WHEREFORE, premises considered, it is respectfully
prayed of this Honorable Court that the cash bond posted by
the accused in the total amount of EIGHT THOUSAND PESOS
(Php8,000.00) be RELEASED.
Other relief and remedies, just and equitable, are
likewise prayed for.
Quezon City, Metro Manila, 23 March 2016.
Assisted by:
PUBLIC ATTORNEYS OFFICE
QUEZON CITY DISTRICT OFFICE
Rm. B-29 Hall of Justice Building
Diliman, Quezon City

DONGIL T. CALUGAY
Public Attorney
Roll of Attorneys No. 64426
IBP No. 1022737; Pangasinan
(Admitted to Philippine Bar on 04-282015)
Cf:
BRANCH CLERK OF COURT
Metropolitan Trial Court
Branch 43
Greetings!
Kindly submit the foregoing motion for the
consideration and approval of this Honorable Court
immediately upon receipt hereof.
DONGIL T. CALUGAY