REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

SIXTH JUDICIAL REGION
KALIBO, AKLAN
PEOPLE OF THE PHILIPPINES
Plaintiff,
Criminal Case No. 9562
For: QUALIFIED THEFT

-versusANTONIO TACUD, ET. AL

Accused.
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MOTION FOR BAIL

COMES NOW, the accused JONEL TACUD, through the
undersigned counsel and unto this Honorable Court most
respectfully pleads:
1. That JONEL TACUD is one of the accused in the charge
for Qualified Theft but he was not yet served a warrant
of arrest;
2. That he needs to be out on bail so he may continue
doing his job and provide for his three minor children
and wife who are all fully dependent on him for
sustenance;
3. That, except for one, all the judges in the Regional Trial
Court of the Province of Aklan are reportedly out of
town for a seminar in Boracay Island, hence, none
among them can act on the application of the accused
for bail, except the remaining Acting Executive Judge;
4. That the right to bail is a Constitutional, statutory and
moral right of the accused before any judgment is
rendered against him in the above-entitled case;
5. That the accused has already paid in cash to the Office
of the Clerk of Court the reduced amount of bail
determined by the court for his provisional liberty, as

evidenced by the Official Receipt issued by the said

office, a copy of which is hereto attached as Annex A.
6. That the accused undertakes to abide by all the
conditions the Court may impose in granting this
Motion.
WHEREFORE, it is most respectfully prayed of the
Honorable Court that an Order be issued to release the
accused JONEL TACUD on bail.
Other reliefs and remedies just and equitable are
likewise prayed for.
Kalibo, Aklan, Philippines; March 15, 2016.