REPUBLIC OF THE PHILIPPINES

METROPOLITAN TRIAL COURT

NATIONAL CAPITAL JUDICIAL REGION
PARANAQUE CITY
BRANCH _______

PEOPLE OF THE PHILIPPINES

- versus - CRIM. CASE NO. ___________

for: Violation of PD 1602

ROCHELYN ALVARADO y VICETAS,

JULIE ANN BENIZA y MARCAIDA,
JACQUILYN PALATINO y DESAMPARADO,
Accused.
x--------------------------------------------------x

MOTION TO POST AND REDUCE BAIL

ACCUSED, ROCHELYN ALVARADO y VICETAS, JULIE ANN

BENIZA y MARCAIDA and JACQUILYN PLATINO y DESAMPARADO,
by themselves and unto this Honorable Court, most respectfully moves
for the reduction of the bail for the above-entitled case and further
avers:

1. Accused are charged for VIOLATION OF PD 1602 before

this Honorable Court;

2. The Bail Recommended for the above-entitled case in in the

amount of TEN THOUSAND PESOS (P10,000.00) each;

3. Accused are currently in dire of financial difficulties and

could not raise the recommended bail;

4. Although with much difficulty, through their benevolent

relatives, they would like to post bail if the same will be
reduced to fifty percent 50% of Php5,000.00 each and to
post cash bond in the said amount.
 PRAYER

WHEREFORE, in the interest of justice and to comply with the

accused’s constitutional right to bail, it is most respectfully prayed of
this Honorable Court that the recommended bail from Php10,000.00 for
each accused be reduced to Php5,000.00 for each accused and the
accused be allowed to post cash bond in its reduced amount for their
provisional liberty, pending the outcome of the case above-stated.

Other reliefs, just, equitable and proper under the premises, are
likewise prayed for.

Respectfully submitted, Paranaque City, April 11, 2018.

ROCHELYN ALVARADO y VICETAS,

JULIE ANN BENIZA y MARCAIDA,

JACQUILYN PALATINO y DESAMPARADO,

Accused.

THE CLERK OF COURT

OFFICE OF THE EXECUTIVE JUDGE
METROPOLITAN TRIAL COURT
PARANAQUE CITY

GREETINGS:

Please submit the foregoing Motion for the kind consideration and
approval of the Honorable Court immediately upon receipt hereof.

ROCHELYN ALVARADO y VICETAS,

JULIE ANN BENIZA y MARCAIDA,

JACQUILYN PALATINO y DESAMPARADO,

Accused.

copy furnished:

OFFICE OF THE CITY PROSECUTOR

REPUBLIC OF THE PHILIPPINES )
CITYO F PARANAQUE )

AFFIDAVIT OF UNDERTAKING

I, JACQUILYN PALATINO y DESAMPARADO, of legal age, single,

Filipino citizen and presently residing at 75-C Ilang-Ilang St., Phase 2,
Bernabe Subdivision, Barangay San Dionisio, Paranaque City, after having
been duly sworn to in accordance with law, hereby depose and say:

1. That I am the accused in Criminal Case No. _________ for the offense
of Violation of PD 1602 pending before the Metropolitan Trial Court,
Branch ______, Paranaque City;

2. That this undertaking shall be effective upon approval and unless

cancelled, shall remain in force at all stages of the case until
promulgation of the judgment of the Honorable Metropolitan Trial
Court, Paranaque City, Branch ______, irrespective of whether the
case was originally filed in or appealed to it;

3. That the affiant undertakes to be present to the Court for the

presentation of her defense if she deems it necessary;

4. That failure of the accused to appear at the trial without justification

and despite due notice shall be deemed a waiver of her right to be
present there at and to be properly identified by the witness, In such
case, the trial may proceed in absentia;

5. That the accused shall surrender herself to the Court during the
promulgation of the judgment;

6. That I am executing this Affidavit of Undertaking to attest to the truth

of all foregoing facts;

IN WITNESS WHEREFORE, I have hereunto affixed my signature

this ______________ at Paranaque City

JACQUILYN PALATINO y DESAMPARADO

Affiant

SUBSCRIBED AND SWORN to before me this ______________, affiant

exhibiting to me her Community Tax Certificate No. _________________
issued on ________________ at ___________________.

NOTARY PUBLIC

Doc. No. ______;

Page No. ______;
Book No. ______;
Series of 2018.
 April 11, 2018

TO WHOM IT MAY CONCERN:

THIS IS TO AUTHORIZE THE BEARER, MS. ARMINDA G. SIBAL,

whose signature appears below, to process on our behalf our motion to
release and reduce bail pending before this Honorable Court and to sign or
secure any documents relative thereto.

ROCHELYN ALVARADO y VICETAS,

JULIE ANN BENIZA y MARCAIDA,

JACQUILYN PALATINO y DESAMPARADO,

ARMINDA G. SIBAL