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Voluntary Surrender With Joint Motion To Reduce Bail: Republic of The Philippines

Danrick D. Gavino and Mark Anthony D. Mellano voluntarily surrendered to the court for the crime of estafa through falsification of public documents. They filed a joint motion to reduce their bail amount from PHP 40,000 each to PHP 20,000 each, as they claim to have no stable income and families to support. They state they were only able to produce PHP 20,000 each by borrowing from relatives. They profess their innocence and undertake to attend all hearings and comply with court conditions for provisional liberty. They pray the court notes their surrender, lifts the arrest warrant, and grants their motion to reduce bail.

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Sheron Biase
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268 views3 pages

Voluntary Surrender With Joint Motion To Reduce Bail: Republic of The Philippines

Danrick D. Gavino and Mark Anthony D. Mellano voluntarily surrendered to the court for the crime of estafa through falsification of public documents. They filed a joint motion to reduce their bail amount from PHP 40,000 each to PHP 20,000 each, as they claim to have no stable income and families to support. They state they were only able to produce PHP 20,000 each by borrowing from relatives. They profess their innocence and undertake to attend all hearings and comply with court conditions for provisional liberty. They pray the court notes their surrender, lifts the arrest warrant, and grants their motion to reduce bail.

Uploaded by

Sheron Biase
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
  • Motion for Voluntary Surrender and Bail Reduction: This section introduces the voluntary surrender motion by the accused with a request to reduce bail amount, alleging no flight risk and inability to afford previous bail terms.
  • Prayer for Bail Reconsideration: Details the formal prayer request for bail reconsideration, reducing the bail amount citing financial constraints.
  • Formal Notice and Certification: This section provides formal communication to the court and interested parties that the motion has been submitted for consideration.

Republic of the Philippines

Third Judicial Region


Regional Trial Court
Branch 63
Tarlac City, Tarlac

People of the Philippines


Complainant,
NPS Docket No. III-17-INV-17D-
00284

-versus- FOR: Estafa through Falsification


of Public Documents

DANRICK D. GAVINO and


MARK ANTHONY D. MELLANO
Accused.

Voluntary Surrender with


Joint Motion to Reduce Bail
The Accused, DANRICK D. GAVINO and MARK ANTHONY D.
MELLANO, unto this Honorable Court, most respectfully and voluntarily
surrenders to the Honorable Court, and moves for the Reduction of Bail, in the
instant case, thus allege:

1. That the present case was raffled to the Honorable Court;

2. That the bail recommended by the Honorable Public Prosecutor for the
provisional liberty of both Accused, is in the amount of FORTY
THOUSAND PESOS ( PhP 40,000.00) each;

3. That both Accused have no stable and definite income, and both have a
family to provide for, and therefore have no sufficient means, to produce
the aforementioned amount;

4. That it was through their relatives that they were able to produce only
the amount of TWENTY THOUSAND PESOS (PhP20,000.00) each,
by borrowing from the said persons;

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5. That both Accused professes their innocence and undertakes to attend
every hearing and comply with all the conditions, set by the Honorable
Court, for their provisional liberty;

6. That this motion is filed solely for the above-reason and not intended to
delay the prompt disposition of this case.

PRAYER

WHEREFORE, premises considered, it is respectfully prayed of this


Honorable Court to:

1. Note the Voluntary Surrender of both Accused and Lift the Warrant of
Arrest;

2. To grant the foregoing Motion, and reduce the recommended amount of bail
from FORTY THOUSAND PESOS ( PhP 40,000.00) each to TWENTY
THOUSAND PESOS (PhP20,000.00) each;

3. Subject to the payment of the said amount, to order the provisional release of
the both Accused.

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

RESPECTFULLY SUBMITTED, this 20th day of September 2017, at


Tarlac City,Tarlac, Philippines.

DANRICK D. GAVINO MARK ANTHONY D. MELLANO

Notice

THE BRANCH CLERK OF COURT


Municipal Trial Court
Branch 1
Justice Hall, Tarlac City, Tarlac

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Please submit the foregoing motion for the consideration and approval of
this Honorable Court upon receipt hereof.

And

THE HONORABLE PUBLIC PROSECUTOR


Regional Trial Court
Branch 63
Justice Hall, Tarlac City, Tarlac

Please take notice that the foregoing motion has been submitted for the
consideration and approval of this Honorable Court upon receipt hereof.

DANRICK D. GAVINO MARK ANTHONY D. MELLANO

COPY FURNISHED:

THE HONORABLE PUBLIC PROSECUTOR


Justice Hall, Tarlac City

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