Republic of the Philippines
REGIONAL TRIAL COURT
9th Judicial Region
Branch 13
Zamboanga City
PEOPLE OF THE PHILIPPINES CRIMINAL CASE NO. xxx
Plaintiff,
- versus - -for-
xxx, Violation of Section 11, Article II
of Republic Act No. 9165
Accused.
x-----------------------x
MOTION FOR RECONSIDERATION REINSTATEMENT OF
BAIL BOND (TOOTH ACHE)
COMES NOW, the Accused through the undersigned counsel,
unto this Honorable office, most respectfully states, that:
1. On August 16, 2018, is suffering from severe toothache on
his right side of the face. As such, he consulted his dentist
Dr. ____________, who advised him to take prescription
medication and to rest for two (2) days. A dental
prescription dated August 16, 2018 is hereto attached as
ANNEX “A”;
2. On the same day of August 16, 2018 and on August 17, 2018,
Accused had a scheduled hearing before this honorable
court at 8:30 o’clock in the morning. However, due to the
severe toothache, Accused was unable to attend both of the
above mentioned hearing;
3. Accordingly, due to the absence of the accused, this
honorable court ordered the cancellation of the bail bond
and a warrant for arrest was issued against the accused;
4. It was never the intention of the accused to ignore and to
absent himself from the scheduled hearing dates, but in fact,
he was unable to attend the same due to the pain from his
toothache. Furthermore, he was advised by his dentist to
take a rest lest the pain exacerbates;
5. This motion is not intended for delay but solely for the
above-mentioned grounds.
1
IN VIEW OF THE FOREGOING, it is most respectfully
prayed of this Honorable Court that:
a. The explanation for the non-appearance of the accused during the
scheduled hearing on August 16 & 17, 2018 at 8:30 o’clock in the
morning be considered satisfactory;
b. The warrant of arrest be recalled and the bail bond of the accused
be reinstated; and
c. To grant other relief and remedies that is just and equitable under
the premises.
Respectfully submitted.
Zamboanga City, Philippines, August 28, 2018
xxx
Accused
Assisted by:
ATTY. xxx
xxx Law Offices
xxx, Zamboanga City
P.T.R. No. _______; Z.C.; _______
I.B.P. No. _______; Z.C.; _______
Roll of Attorney No. _______
M.C.L.E. Compliance No. V-_______; _______
Copy furnished:
_______
Office of the City Prosecutor
Hall of Justice, Sta. Barbara
Zamboanga City