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Zabate - MR - Ra 6539

This motion requests the release of a property bail bond that was previously forfeited due to the non-appearance of the accused, Julio Zabate. It summarizes that Zabate has now been detained since July 4, 2017, so the purpose of the bond is fulfilled. It asks the court to have mercy on the elderly owner of the property and release the bond now that Zabate is in custody. The public attorney respectfully requests an order to release the property bail bond.

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144 views2 pages

Zabate - MR - Ra 6539

This motion requests the release of a property bail bond that was previously forfeited due to the non-appearance of the accused, Julio Zabate. It summarizes that Zabate has now been detained since July 4, 2017, so the purpose of the bond is fulfilled. It asks the court to have mercy on the elderly owner of the property and release the bond now that Zabate is in custody. The public attorney respectfully requests an order to release the property bail bond.

Uploaded by

Jqdomingo88
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 DOC, PDF, TXT or read online on Scribd
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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT


11TH JUDICIAL REGION
BRANCH 34
PANABO CITY

THE PEOPLE OF THE X------------------------------------x


PHILIPPINES,

-versus- CRIMINAL CASE NO. 64-2005

JULIO ZABATE, R.A. 6539


et. al.,
Accused.

EX PARTE MOTION TO
RELEASE (PROPERTY) BAILBOND
WITH AD CAUTELAM MOTION FOR RECONSIDERATION
(of the order dated February 2, 2015)

Petitioner JULIO ZABATE, through the undersigned public attorney,


respectfully submits this motion, stating THAT;

1. This Honorable Court, in its order dated February 2, 2015


promulgated a decision on the above-mentioned case;

2. This Honorable Court, found in the said Order that due to the
continued non-appearance of the above-named accused the
property bond covered by OCT No. P-11728 was ordered forfeited in
favor of the State;

3. As per attached Certificate of Detention, however, the above-


named accused has been under police custody since July 4, 2017.

4. The owner of the said property bond forfeited, is an elderly, who


now comes to the mercy of this Honorable Court for her to be able
to recover the property forfeited given that Julio Zabate is now
already in custody.

5. The property bond posted is under the charge of this Honorable


Court.

WHEREFORE, based on the foregoing, petitioner respectfully prays


that an order be issued for the release of the PROPERTY BOND covered by
OCT No. P-11728.

Other reliefs just and equitable under the premises are equally prayed
for.
RESPECTFULLY SUBMITTED.
Panabo City, Davao del Norte, Philippines. 27th of October, 2017.

JOAHNA PAULA Q. DOMINGO


Public Attorney I
PTR No. 9195872; 07/04/2017
IBP O.R No. 006046
Roll No. 67043
Admitted to Bar May 2017

NOTICE OF HEARING/SUBMISSION

The Branch Clerk of Court


RTC Branch 34

Pros. Rocarma Nuesca

Please take notice that the undersigned counsel submitted the foregoing for
the consideration of this Honorable Court on October 27, 2017 without prejudice to
further appearance and oral arguments which may be required by the court of the
undersigned counsel.

JOAHNA PAULA Q. DOMINGO

Copy furnished:

PANABO CITY PROSECUTIONS OFFICE


Panabo City, Davao del Norte

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