REPUBLIC OF THE PHILIPPINES

FOURTH JUDICIAL REGION

MUNICIPAL TRIAL COURT IN CITIES
IMUS, CAVITE

THE PEOPLE OF THE PHILIPPINES,

Plaintiff,
-versus-

Criminal case No. 14-27704

Attempted Homicide

RICHARD JUSTO y MOLINA,

Accused.
x-----------------------------------------x
x=====================================================x

ENTRY OF APPEARANCE
with
URGENT MOTION TO REDUCE BOND

COMES

NOW

UNDERSIGNED

LAW

FIRM,

unto

this

Honorable Court most respectfully enters its appearance as counsel

for accused RICHARD JUSTO y MOLINA in the above-entitled case
and respectfully states that:
1. Herein accused had been under detention since April 14, 2014. In
addition to the above case which charges herein accused of
attempted

homicide

(Criminal

Case

No.

14-27704)

with

recommended bail of twelve thousand pesos (Php 12, 000.00), there

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are two (2) Informations that are filed arising from the same
incident against herein accused Richard Justo y Molina before the
Regional Trial Court Branch 20 of Imus, Cavite: one is for
Frustrated

Murder

(Criminal

Case

No.

13457-14)

with

recommended bail of Php 200, 000.00 and the other Information

charged the accused of Theft (Criminal Case No. 13456-14) with a
recommended bail of Php 40, 000.00. Accused has also filed his
Motion to Reduce Bail on the aforementioned cases before Branch
20 of the Regional Trial Court of Imus, Cavite.
A copy of the Information on the Attempted Homicide charge is
hereto attached as ANNEX A;
5. The amount of Php 12, 000. 00 recommended bail bond for
attempted homicide against herein accused together with the
recommended bail of Php 40, 000.00 in the theft case (Criminal
Case No. 13456-14) and the recommended bail of Php 200, 000.00
in Frustrated Murder (Criminal Case No. 13457-14) before the
Regional Trial Court Branch 20 of Imus, Cavite or a total amount of
Php 252, 000. 00 is beyond his means and capacity to pay as herein
accused is an indigent and belongs to the marginalized sector of the
society as evidenced by the Certificate of Indigency, which is hereto
attached as ANNEX B;
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3. Herein accused is twenty-eight (28) years old and a father of

two minor children named Aaron, who is turning three (3) and
Caleb who is turning two (2). Accused gets to put food on the table
for his family by getting painting jobs, though, on irregular basis.
While accused may not have permanent job, he is doing his best to
provide for his family. While being under detention, no one could
provide for his two young children as his live-in partner is likewise
without a job. The accused may be poor but he cannot turn back
from his responsibility to his children by escaping the legal
procedures of this Honorable Court. It is his children who would
foremost suffer in the event he chooses to abscond from the legal
processes of the law;

6. The lack of financial capacity and his responsibility to his two minor
children, who would be left with no one to care and provide in case
he absconds, are the factors that would ensure accuseds presence
during the trial of this case. There is no risk or possibility of flight

on the part of herein accused. With the condition and financial

status of the accused, he could not even provide for the basic
necessities of his family. How much more could he post for the
amount of Php 12, 000.00 considering that he has still to post for

bail in the total amount of Php 240, 000.00 in the other two charges
filed against him?
We beseech the kind heart and compassion of this Honorable
Court to reduce the amount of bail from Php 12, 000.00 to Php 6,
000.00 for the charge of Attempted Homicide.
On bended knees and for humanitarian consideration, and in
light of the Constitutional right of the accused to be presumed
innocent, we fervently pray for the reduction of bail.

PRAYER

WHEREFORE PREMISES CONSIDERED, it is respectfully

prayed unto this Honorable Court that the Entry of Appearance be
Noted and undersigned law firm shall be furnished copies of any
pleading, order or court processes relative to the above case in its
given address; and to reduce the recommended bail for the charge
of attempted homicide in the amount of Php 12, 000.00 to SIX
THOUSAND PESOS (Php 6, 000.00).
Other reliefs just and equitable in the premises are likewise
sought.
RESPECTFULLY SUBMITTED.
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May 27, 2014 Makati City for Imus Cavite.

ESTELLA AND VIRTUDAZO LAW FIRM

Counsel for the Accused

Suite 5B, 5th Floor, Electra House Building

115 Esteban Street, Legaspi Village, Makati City
Tel. Nos. 8127608/8403028

By:

VICENTE E. BALTAZAR, JR.

PTR No. 4229286, Jan. 03, 2014, Makati City
IBP O. R. No.950393, Jan. 03, 2014, Manila II
Roll of Attorneys No. 54219
MCLE Compliance No. IV-0009972, Dec. 5, 2012

and
HELEN GRACE J. SOMERA
PTR No. 4229285, Jan. 03, 2014, Makati City
IBP O.R. No. 950394, Jan. 03, 2014, Manila II
Roll of Attorneys No. 57138
MCLE Compliance No. IV-0010224, Dec. 11, 2012
COPY FURNISHED AND NOTICE OF HEARING

The Clerk of Court

Municipal Trial Court in Cities
5

Imus, Cavite
The City Prosecutors Office
Imus Cavite

Greetings:
Please be informed that undersigned counsel hereby request to
submit the foregoing motion for the consideration and approval of
the Honorable Court on June 2, 2014 at 1:30 in the afternoon.

HELEN GRACE J. SOMERA