Republic of the Philippines

REGIONAL TRIAL COURT

Second Judicial Region
Branch 23
Roxas, Isabela

PEOPLE OF THE PHILIPPINES,

Plaintiff

-versus- Crim. Case No. Br. 23-3002

EMHER PINAROC
Accused.
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MOTION FOR RECONSIDERATION

The undersigned for and in behalf of the bondsman, Alpha

Insurance & Surety Company, unto this Honorable Court, most
respectfully states that:

1. The hearing of the above-captioned case was set on

September 8, 2017. Regrettably however, the accused
failed to appear for her scheduled arraignment on said
date.

2. In this regard, on June 27, 2018, the undersigned

received the Order dated September 8, 2017 directing the
bondsman to show cause why no judgment shall be taken
against the surety bond.

3. The undersigned hereby implore the forbearance of the

Honorable Court and excuse the bondsman for the
absence of the accused on his scheduled hearing.

4. The undersigned hereto moves for the reconsideration of

the September 7, 2018 Order on the following
considerations, to wit:

a. That the herein bondsman, due to her health

condition, has been undergoing series of
medical examinations during that span of time
and even up to now.

b. That the herein bondsman, due to the above-

mentioned reason, had inadvertently failed to
delegate to her secretary the duty to inform the
accused of his scheduled hearing.
 5. The undersigned begs the forgiveness of the Honorable
Court and undertakes to avoid repetition of the same act;

6. This motion is made in good faith and not intended to

delay the proceedings of the instant case;

WHEREFORE, it is most respectfully prayed to this Honorable

Court that the ORDER dated September 7, 2018 be reconsidered
and set aside, and that the bondsman be given a period of 30 days
within which to produce the body of the accused before this court.

Other reliefs just and equitable are likewise prayed for.

Cauayan City, Isabela, July 25, 2018.

ALPHA INSURANCE & SURETY COMPANY,

INC.
By:

MYRNA FELY D. RESURRECCION

Bondsman

NOTICE

THE BRANCH CLERK OF COURT

Regional Trial Court
Branch 23
Roxas, Isabela

Greetings:
Kindly submit the foregoing motion immediately upon receipt
hereof for its kind consideration and approval.
ALPHA INSURANCE & SURETY COMPANY,
INC.

By:

MYRNA FELY D. RESURRECCION

Bondsman

Copy Furnished:

OFFICE OF THE PROSECUTOR

Roxas, Isabela