REPUBLIC OF THE PHILIPPINES

THIRD JUDICIAL REGION

REGIONAL TRIAL COURT
Malolos City

PEOPLE OF THE PHILIPPINES,

Plaintiff,
- versus- NPS DOCKET NO. III-04-
INQ-18E-00886

ELEUTERIO ODITOR y DAMOLO, ET. AL.,

Accused.
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MOTION TO FIX BAIL

Accused, on their own behalf, respectfully alleges:

1. That accused ELEUTERIO ODITOR y DAMOLO, MELANIE

BERMALO y RAPOL, AGNES ESTEPONA y RIGAYA, JENNY
RESURRECION y CUARTERTO and DENNIS MAUREAL y
BADA are currently detained at the Guiguinto Municipal Jail for
the charge of Violation of Election Liquor Ban and has been
behind bars since their arrest on May 14, 2018;

2. That it would be advantageous to everyone if they will be given

temporary liberty;

3. As such, accused appeal to the mercy and compassion of this

Honorable Court and respectfully requests that their bail be fix at
a reasonable amount;

4. That this motion to fix bail is being filed without prejudice to any
other remedy which may be available to the accused and that the
accused expressly reserves the right to question the legality of
their warrantless arrest if the circumstances would so warrant.

WHEREFORE, it is respectfully prayed of this Honorable Court

that accused be allowed to post bail for their temporary liberty pending
resolution of the criminal charge against them.

Other relief just and equitable are likewise prayed for.

Malolos City, Bulacan, Philippines, May 17, 2018.

 _______________________________
JHON REYNALD REYES y LUMANOG

__________________________
ANA MARIE REYES y LUMANOG

NOTICE OF HEARING

Greetings:

Kindly submit the foregoing for its consideration and approval.

___________________________
ELEUTERIO ODITOR y DAMOLO

_________________________
MELANIE BERMALO y RAPOL

_________________________
AGNES ESTEPONA y RIGAYA

_________________________________
JENNY RESURRECION y CUARTERTO

_______________________
DENNIS MAUREAL y BADA