Republic of the Philippines
REGIONAL TRIAL COURT
7th Judicial Region
BRANCH 56
Naga City
PEOPLE OF THE PHILIPPINES,
Plaintiffs, CRIM. CASE NO. _____________
-versus -
FOR: VIOLATION OF SEC. 5 and SEC. 11,
JERVIE ISIDRO PERAME OF RA9165 (THE COMPREHENSIVE
Accused, DRUGS ACT OF 2002 DANGEROUS
X ------------------------------------- /
MOTION TO POST BIL BOND,
TO PLEA BARGAIN AND
TO AVAIL FREE LEGAL ASSISTANCE
COMES NOW, the accused thru this verified instruments unto this Honorable
Court most respectfully submit this verified pleadings and do hereby deposed and say
that-
1. Accused vehemently denied, the allegations of the four(4) arresting officer in their
narrated statement of their judicial complaint affidavits;
2. Sometimes on June 8, 2023 at around 6:30 evening while the accused having took his
dinner at La Espelita Carenderia located at Tungkop Minglanill, Cebu herewith attached the
photos of La Espelita Carenderia where the dining table that I supposed to take my dinner
as Annex-A hereof;
3. He notice the Inova Sedan Van color gray bearing the plate no. 827 arrived nearby the
carenderia part along the road, on this juncture he saw four civilian men wearing a face
bonet approaching to his table and suddenly ask a question are you Jervie Perame?, then I
also question them who are you guys? And they did not answer on that particular time my
mother called me up and I answered my cell phone using my right hand while my left hand
has the pork and spoon. However without any provocation the socalled the four approached
the dining table and outright pick up me and brought to the said vehicle and I also saw some
arrested persons inside the said van and they brought us to the subdivision which I did not
know where;
4. Accused was illegally arrested without a warrant of arrest clearly abducted this innocent
victim after that they brought as to the detention at Minglanilla police station;
5. The rules engagement was not properly implemented there was no By Bust Operation
conducted, aside that the accused not positive the bringing the so called alleged shabu
because during the time he was going to eat his dinner inside that La Espelita Carenderia
located at Tungkop Minglanilla;
6. Accused was innocent of the socalled manipulated evidence as allegedly indicated in
SEC.5 having 0.08 gram of shabu, while in SEC. 11 having 0.06 grams of shabu as their
so-called evidence as they submitted to this Honorable Court are tantamount considered
just like a poisonous tree;
7. During that illegal arrest accused, was suffering mental anxiety because his beloved wife
was died last May 28, 2023 living an 8 years old child his daughter that needs the loving
comfort of this poor accused as her father. Accused categorically considered as indigent
who was just mere barber as the bread winner of this poor family and cannot afford to hire
private lawyer to assist in this instance case, and hoping the acceptance of the free legal
assistance through ATTY. GEMINI ALCANATARA the OIC Public Attorney’s Office Naga
City, Cebu Province. Herewith attached the affidavit of the Certificate of Indigency,
Certificate of Residency with sketch plan issued by the Brgy. Capt. Guindaruhan Minglanilla
Cebu as Annex-B-1, B-2 and the death certificate of the late Richelle Depareni my live-in
partner and the picture of my daughter as Annexes- C-3 and C-4 hereof;
8. The quantity of dangerous drug involved in Sec. 5 and SEC. 11 of Shabu was being
planted not actually taken in my possession as I had clearly stipulated indicated of this
instrument;
9. Accused is likewise praying that an Order be issued directing to the detention cell at
Minglanilla police station, to allow the accused to undergo drug dependency examination to
be conducted by any DOH accredited physician and drug screening test and furnish copy of
the results to this Honorable Court;
10. Accused humbly begs for the Honorable Court’s compassion to allow her to Post Bil
Bond of SEC. 5 and SEC. 11 as a plea bargaining;
11. This motion is made in good faith and not to cause unnecessary delay.
PRAYER
WHEREFORE, premises considered, it is most respectfully prayed that the instant
Motion be GRANTED for the SEEK of humanitarian reconsideration to avail the following:
1. To have free legal assistance from the Public Attorney’s Office;
2. To allow to post in posting bill of SEC. 5 and SEC.11 to thru surety bonding company.
3. To be retain at Minglanilla Police Station Detention Center while the socalled case still
ongoing to this Honorable Court.
FURTHERMORE, Accused prayed the dismissal of this instant case for lack of Merits
Other relief and remedies are also Prayed for.
Respectfully submitted on this ____ day of July 2023, at Cebu City( for Naga City), Cebu
Province Philippines.
JERVIE ISIDRO PERAME,
Allege Accused
TAX CERTIFICATE
CC12021 26206110
VERIFICATION AND CERTIFICATION
FOR NON FUROM SHOPPIMG
I, JERVIE ISIDRO PERAME A.K.A. “JER” of legal age, Single, Filipino, address at
Brgy. Guindaruhan Municipality of Minglanilla, Cebu after having been duly sworn according
to law, Do hereby depose and state, That –
I am, have caused the preparation of this instruments, to avail the Liberty of
Freedom and to contest the Complainant’s / Plaintiffs FABRICATED allegations who
intentionally manufactured complaints just to HARRASH the alleged accused, I have read
the entire allegation, contain therein, and the same are true and correct of my own
knowledge and belief. That I have not commenced any other action or proceeding involving
similar issues in the Supreme Court, the Court of Appeals or any Tribunals or Government
agency.
IN WITNESS WHEREOF, I have hereunto set my hands this ___ day of July 2023 in
Cebu City, (for Naga City) Cebu Province, Philippines.
JERVIE ISIDRO PERAME,
Allege Accused
TAX CERTIFICATE
CC12021 26206110
SUBSCRIBED AND SWORN, to before me on this ___ day of July 2023 in Cebu
City, (for Naga City) Philippines, by affiants and I personally examined his Community Tax
Certificate as per attached hereof, indicate below their name and he understood the
contents of this instruments consisting of four (4) pages including this page.
WITNESS MY HAND AND SEAL on the day, year in the place above-written.
Doc. No______
Page No._____
Book No._____
Series of 2023
NOTICE OF SUBMISSION
The Clerk of Court
Regional Trial Court
7th Juditial Region
Branch 56
Naga City, Cebu
Greetings!
Please submit this foregoing instrument to Hon. Francis Larubis the Presiding Judge of
this Honorable Court, appealing the resolution, in granting this motion as the gratitude of
this undersigned accused. Praying, the Post Bill Bond be granted for the seek the
humanitarian reconsideration.
Respectfully submitted of this ___ day of July 2023, Naga City, Cebu.
JERVIE ISIDRO PERAME,
Allege Accused
TAX CERTIFICATE
CC12021 26206110
COPY FURNISHED:
THE HON. PROSECUTOR ATTY. GEMINI ALCANTARA
Cebu Provincial Prosecutor Office Officer In Charge
Department of Justice Public Attorneys Office
Village St., Capitol Site, Cebu City Chapter Naga City
