REPUBLIC OF THE PHILIPPINES

METROPOLITAN TRIAL COURT

THIRD JUDICIAL REGION
MUNICIPALITY OF BACOLOR, PAMPANGA
Branch

PEOPLE OF THE PHILIPPINES,

-versus- Crim. Case No. 3908

RUDY LIBUNAO y MATIAS,

Accused.
x----------------------------------------------------x

URGENT MOTION FOR BAIL

Accused, by counsel, respectfully states that:

1. Accused juan de la cruz, has been charged with violation of Section

103 (Theft of Minerals) of Republic Act No. 7942 otherwise known as the “Philippine
Mining Act of 1995”.

2. The (Agency who issued the recommentdation?) has recommended

the bail be fixed at Thirty Six Thousand Pesos (P36,000) for his provisional release
has been.

3. Rule 114, Section 4 of the Rules of Court provides:

Section 4. Bail, a matter of right; exception. — All

persons in custody shall be admitted to bail as a matter
of right, with sufficient sureties, or released on recognize
as prescribed by law or this Rule (a) before or after
conviction by the Metropolitan Trial Court, Municipal
Trial Court, Municipal Trial Court in Cities, or Municipal
Circuit Trial Court, and (b) before conviction by the
Regional Trial Court of an offense not punishable by
death, reclusion perpetua, or life imprisonment.

4. Accused Libunao is currently being detained in the National Bureau of

Investigation Headquarters in Manila since February 7, 2019 and is thus seeking to
post bail in the present case.

RELIEF
 WHEREFORE, it is respectfully prayed that accused juan de la cruz be
allowed to post bail for his temporary liberty pending trial of the criminal charge
against him.

Clark Freeport Zone for Municipality of Bacolor, Pampanga, February 19,

2019.

By:

JON DOE
ROLL NO.
IBP LIFETIME O.R. NO.
PTR NO.
MCLE COMPLIANCE NO., 07.03.18, PASIG
CITY

VERIFICATION AND CERTIFICATION


, subscribing under oath, depose and state:

1. I am the petitioner in the above-entitled case.


2. I caused the preparation and filing of the foregoing Urgent Motion For
Bail. I have read and understood the foregoing Petition, and all the allegations
therein are all true and correct of our personal knowledge and/or based on authentic
records.

3. I have not commenced any other action or proceeding involving the

same issues in any other tribunal, to the best of our knowledge no such action or
proceeding is pending in any other tribunal, and should we learn that a similar action
or proceeding has been filed or is pending before any tribunal, we undertake to
report that fact to this Honorable Court within five (5) days therefrom.

SUBSCRIBED AND SWORN to before me this 19th day of February in Manila

City, by the affiant who is personally known to me to be the same person who
executed the foregoing verification and certification exhibiting his LTO Drivers
License No.

Doc. No. _____;

Page No. _____;
Book No. _____;
Series of 2019.

NOTICE OF HEARING AND COPIES FURNISHED TO:

THE CLERK OF COURT
Branch, Metropolitan Trial Court
Municipality of Bacolor, Pampanga

KAGAWARAN NG KATARUNGAN
Task Force on Environmental Cases
Manila City

Greetings:

Please take notice that the foregoing Urgent Motion For Bail will be submitted
for the Honorable Court’s consideration and resolution on immediately upon receipt
sans further arguments.