Republic of the Philippines

SECOND JUDICIAL REGION

3RD MUNICIPAL CIRCUIT TRIAL COURT
(TUMAUINI – DELFIN ALBANO)
Tumauini, Isabela

PEOPLE OF THE PHILIPPINES,

Plaintiff, CRIM CASE NO. 3782

-versus- FOR:

GERRY BUMANGLAG y GALAM, VIOLATION OF RA 9484

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

MOTION FOR RECONSIDERATION

ON ORDER DATED JULY 16, 2021

ACCUSED thru the Public Attorney’s Office and unto the Honorable Court,
most respectfully moves for the reconsideration of its Order dated July 16, 2021,
thus:

1. The accused received the aforesaid Order on August 3, 2021, the

pertinent portion thereof states:

“In today’s hearing, submitted before this Court is a Post Sentence

Investigation Report filed by Leon S. Alchanzar, Jr., Supervising
Probation and Parole Officer of Isabela Parole and Probation
Office, Ilagan City.

It has come to the attention of this Court that the fine of Two
Hundred (P200,000.00) Pesos which was imposed was yet settled
by the applicant.

Before this Court approve the Probation of the said applicant, let
the Two Hundred Thousand (P200,000.00) Pesos fine be paid in
Court.”

2. With all due respect, the aforesaid Order has no basis in law.

3. The Probation Law (PD 968)1 is very clear.

Section 5. Post-sentence Investigation. No person shall be placed on

probation except upon prior investigation by the probation officer and a
determination by the court that the ends of justice and the best interest of
the public as well as that of the defendant will be served thereby.

4. The Probation of the accused was favorably recommended for by the

Parole and Probation Officer per his Post Sentence Investigation Report.

5. However, the Court insists that the accused must settle his sentence
which pay the fine of Two Hundred Thousand (P200,000.00) Pesos.

1
ESTABLISHING A PROBATION SYSTEM, APPROPRIATING FUNDS THEREFOR AND
FOR OTHER PURPOSES
 6. The accused humbly informs the Court that he is now indigent after he
was charged with this case and as a consequence, he secured the
services of the Public Attorney’s Office. He cannot settle the fine simply
because he is financially incapable of doing so.

7. Further, the Probation Law states that:

Section 4. Grant of Probation. Subject to the provisions of this Decree,

the court may, after it shall have convicted and sentenced a defendant
and upon application at any time of said defendant, suspend the execution
of said sentence and place the defendant on probation for such period and
upon such terms and conditions as it may deem best.

Probation may be granted whether the sentence imposes a term of

imprisonment or a fine only. Xxx xxx xxx

8. While not all applications for probation may be granted, the law is very
specific as to who are disqualified per Section 8 2 and 93 of PD 968.

9. The accused is very much qualified as he is not one of those mentioned in

Section 8 and 9 of PD No. 968. Non payment of fine is not one of the
grounds for the disqualification of accused for probation. His nonpayment
of fine is simply because of his indigency per Certification of Indigency
attached hereto as Annex “A.”

10. The accused/s most respectfully begs and prays the Honorable
Court to approve the accused Application for Probation.

PRAYER

WHEREFORE, premises considered, accused respectfully begs and

prays that his Application for Probation be APPROVED.

Other reliefs, just and equitable under the circumstances, are likewise
prayed for.

2
In determining whether an applicant may be granted probation, the court takes into
consideration all the information relative to the character, antecedents, environment,
mental and physical condition of the offender and available institutional and community
resources. It shall deny the application for probation of a convicted offender if it finds
that: 1) the offender is in need of correctional treatment that can be provided most
effectively by his commitment to an institution; 2) there is an undue risk that during the
period of probation the offender will commit another crime; or 3) probation will
depreciate the seriousness of the offense committed (Section 8, PD 968).
3
In addition, the benefit of probation shall also not be granted to the following
disqualified offenders: 1) those who have been sentenced to serve a maximum term of
imprisonment of more than six (6) years; 2) those who are convicted of subversion or any
crime against the national security or the public order; 3) those who have previously been
convicted by final judgment of an offense punished by imprisonment of not less than one
month and one day and/or a fine of not less than two hundred pesos; 4) those who have
been once on probation under the provisions of this decree; and 5) those who are already
serving sentence at the time the substantive provisions of this decree became applicable
pursuant to Section 33 hereof (Section 9, Ibid.)
 Cabagan, Isabela, August 11, 2021.

Department of Justice
Public Attorney’s Office
CABAGAN DISTRICT OFFICE
Cabagan, Isabela

By:

NICANOR G. GARCIA
District Public Attorney

MARICION B. CAPILI-GUINGAB
Public Attorney II

With my Conformity:

THE PUBLIC PROSECUTOR

OPP – City of Ilagan, Isabela

NOTICE OF HEARING

THE CLERK OF COURT

3rd MCTC
Tumauini, Isabela

THE PUBLIC PROSECUTOR

Counsel for the Plaintiff

GREETINGS:

Please take notice that the undersigned will be submitting the instant
motion for the appreciation and consideration of the Honorable Court
immediately upon receipt hereof.

MARICION B. CAPILI-GUINGAB

Copy Furnished:

Pros. JOHANS S. GONZAGA

OPP -Ilagan City, Isabela Registry Receipt No.: ________________
Date: ________________
 Republic of the Philippines
SECOND JUDICIAL REGION
ND
2 MUNICIPAL CIRCUIT TRIAL COURT
(CABAGAN – SANTO TOMAS)
Cabagan, Isabela

PEOPLE OF THE PHILIPPINES,

Plaintiff, CRIM CASE NO. 4422
-versus- FOR:

VIOLATION OF R.A. NO.

9175

MARGIE ALLAUIGAN y GOLLAYAN,

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

MOTION FOR REDUCTION OF BAIL

ACCUSED, MARGIE ALLAUIGAN y GOLLAYAN, thru the

Public Attorney’s Office and unto the Honorable Court, most
respectfully moves for the reduction of the recommended bail in view
of the following considerations, thus: THAT,

1. The accused under the custody of PNP – San Pablo, Isabela,

being charged of the crime of VIOLATION OF P.D. 1602 with a
recommended bail for her provisional liberty in the amount of
THIRTY THOUSAND PESOS (₱ 30,000.00) ;

2. The accused having no regular income, wishes to post bail for

her provisional liberty however in spite of all the efforts, she
simply cannot produce the aforesaid amount;

3. The accused/s most respectfully begs and prays the Honorable

Court to reduce the aforesaid recommended bail to FIVE
THOUSAND PESOS (₱ 5,000.00).

PRAYER
 WHEREFORE, premises considered, accused respectfully
begs and prays that recommended bail for her provisional liberty be
reduced from THIRTY THOUSAND PESOS (₱ 30,000.00) to FIVE
THOUSAND PESOS (₱ 5,000.00).

Other reliefs, just and equitable under the circumstances, are

likewise prayed for.

Cabagan, Isabela. August 05, 2021.

Department of Justice
Public Attorney’s Office
CABAGAN DISTRICT OFFICE
Cabagan, Isabela

By:

NICANOR G. GARCIA
District Public Attorney

PAUL ERIC C. TAMBOA

Public Attorney II

With my Conformity:

PROS. MA. JEANETTE B. LAYUGAN

OPP – Cabagan, Isabela

NOTICE OF HEARING

THE CLERK OF COURT

2ND MCTC
Cabagan, Isabela

THE PUBLIC PROSECUTOR

Counsel for the Plaintiff

GREETINGS:

Please take notice that the undersigned will be submitting the

instant motion for the appreciation and consideration of the
Honorable Court immediately upon receipt hereof.
 PAUL ERIC C. TAMBOA

Copy Furnished:

OPP - Cabagan Satellite Office

Cabagan, Isabela

Republic of the Philippines

SECOND JUDICIAL REGION
RD
3 MUNICIPAL CIRCUIT TRIAL COURT
(TUMAUINI – DELFIN ALBANO)
Tumauini, Isabela

PEOPLE OF THE PHILIPPINES,

Plaintiff, CRIM CASE NO. _________
-versus- FOR:

VIOLATION OF R.A. NO.

9175

ZIMAR MANAGUELOD y PINTUCAN,

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

MOTION FOR REDUCTION OF BAIL

ACCUSED, ZIMAR MANAGUELOD y PINTUCAN, thru the

Public Attorney’s Office and unto the Honorable Court, most
respectfully moves for the reduction of the recommended bail in view
of the following considerations, thus: THAT,

4. The accused under the custody of PNP – Delfin Albano Isabela,

being charged of the crime of VIOLATION OF R.A. NO.
9175with a recommended bail for his provisional liberty in the
amount of THIRTY SIX THOUSAND PESOS (₱ 36,000.00) ;

5. The accused having no regular income, wishes to post bail for

his provisional liberty however in spite of all the efforts, he
simply cannot produce the aforesaid amount;

6. The accused/s most respectfully begs and prays the Honorable

Court to reduce the aforesaid recommended bail to EIGHTEEN
THOUSAND PESOS (₱ 18,000.00).
 PRAYER

WHEREFORE, premises considered, accused respectfully

begs and prays that recommended bail for his provisional liberty be
reduced from THIRTY SIX THOUSAND PESOS (₱ 36,000.00) to
EIGHTEEN THOUSAND PESOS (₱ 18,000.00).

Other reliefs, just and equitable under the circumstances, are

likewise prayed for.

Cabagan, Isabela, August 03, 2021.

Department of Justice
Public Attorney’s Office
CABAGAN DISTRICT OFFICE
Cabagan, Isabela

By:

NICANOR G. GARCIA
District Public Attorney

MARICION B. CAPILI-GUINGAB
Public Attorney II

With my Conformity:

THE PUBLIC PROSECUTOR

OPP – Cabagan, Isabela

NOTICE OF HEARING

THE CLERK OF COURT

3RD MCTC
Tumauini, Isabela

THE PUBLIC PROSECUTOR

Counsel for the Plaintiff

GREETINGS:

Please take notice that the undersigned will be submitting the

instant motion for the appreciation and consideration of the
Honorable Court immediately upon receipt hereof.
 MARICION B. CAPILI-GUINGAB

Copy Furnished:

Pros. JOHANS S. GONZAGA

OPP -Ilagan City, Isabela

Republic of the Philippines

SECOND JUDICIAL REGION
RD
3 MUNICIPAL CIRCUIT TRIAL COURT
(TUMAUINI – DELFIN ALBANO)
Tumauini, Isabela

PEOPLE OF THE PHILIPPINES,

Plaintiff, CRIM CASE NO. _________
-versus- FOR:

VIOLATION OF PD NO. 1602

ALEXANDER GUIYAB y NARAG,

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

MOTION FOR REDUCTION OF BAIL

ACCUSED, ALEXANDER GUIYAB y NARAG, thru the Public

Attorney’s Office and unto the Honorable Court, most respectfully
moves for the reduction of the recommended bail in view of the
following considerations, thus: THAT,

7. The accused under the custody of PNP – Tumauini, Isabela,

being charged of the crime of VIOLATION OF PD NO. 1602
with a recommended bail for his provisional liberty in the
amount of THIRTY SIX THOUSAND PESOS (₱ 36,000.00) ;

8. The accused having no regular income, wishes to post bail for

his provisional liberty however in spite of all the efforts, he
simply cannot produce the aforesaid amount;

9. The accused/s most respectfully begs and prays the Honorable

Court to reduce the aforesaid recommended bail to EIGHTEEN
THOUSAND PESOS (₱ 18,000.00).
 PRAYER

WHEREFORE, premises considered, accused respectfully

begs and prays that recommended bail for his provisional liberty be
reduced from THIRTY SIX THOUSAND PESOS (₱ 36,000.00) to
EIGHTEEN THOUSAND PESOS (₱ 18,000.00).

Other reliefs, just and equitable under the circumstances, are

likewise prayed for.

Cabagan, Isabela, August 01, 2021.

Department of Justice
Public Attorney’s Office
CABAGAN DISTRICT OFFICE
Cabagan, Isabela

By:

NICANOR G. GARCIA
District Public Attorney

MARICION B. CAPILI-GUINGAB
Public Attorney II

With my Conformity:

THE PUBLIC PROSECUTOR

OPP – Cabagan, Isabela

NOTICE OF HEARING

THE CLERK OF COURT

3RD MCTC
Tumauini, Isabela

THE PUBLIC PROSECUTOR

Counsel for the Plaintiff

GREETINGS:

Please take notice that the undersigned will be submitting the

instant motion for the appreciation and consideration of the
Honorable Court immediately upon receipt hereof.
 MARICION B. CAPILI-GUINGAB

Copy Furnished:

Pros. JOHANS S. GONZAGA

OPP -Ilagan City, Isabela

Republic of the Philippines

SECOND JUDICIAL REGION
RD
3 MUNICIPAL CIRCUIT TRIAL COURT
(TUMAUINI – DELFIN ALBANO)
Tumauini, Isabela

PEOPLE OF THE PHILIPPINES,

Plaintiff, CRIM CASE NO. ______

-versus- FOR:

LAURO GUIYAB y TACCAD, ET. AL., VIOLATION OF P.D.

1602
Accused.
x-----------------------------------------x

MOTION FOR REDUCTION OF BAIL

ACCUSED, LAURO GUIYAB y TACCAD, ROGELIO

TAQUIQUI y GUIYAB and MARLON TAGUINOD y CURUGAN, thru
the Public Attorney’s Office and unto the Honorable Court, most
respectfully moves for the reduction of the recommended bail in view
of the following considerations, thus: THAT,

11. The accused under the custody of PNP – Tumauini,

Isabela, being charged of the crime of VIOLATION OF P.D. 1602
with a recommended bail for their provisional liberty in the amount of
THIRTY THOUSAND PESOS (₱ 30,000.00) EACH;
1.
2. The accused having no regular income, wishes to post
bail for their provisional liberty however in spite of all the efforts, they
simply cannot produce the aforesaid amount;

12. The accused/s most respectfully begs and prays the

Honorable Court to reduce the aforesaid recommended bail to FIVE
THOUSAND PESOS (₱ 5,000.00) EACH.
 PRAYER

WHEREFORE, premises considered, accused respectfully

begs and prays that recommended bail for their provisional liberty be
reduced from THIRTY THOUSAND PESOS (₱ 30,000.00) EACH to
FIVE THOUSAND PESOS (₱ 5,000.00) EACH.

Other reliefs, just and equitable under the circumstances, are

likewise prayed for.

Cabagan, Isabela, August 01, 2021.

Department of Justice
Public Attorney’s Office
CABAGAN DISTRICT OFFICE
Cabagan, Isabela

By:

NICANOR G. GARCIA
District Public Attorney

MARICION B. CAPILI-GUINGAB
Public Attorney II

With my Conformity:

THE PUBLIC PROSECUTOR

OPP – Cabagan, Isabela

NOTICE OF HEARING

THE CLERK OF COURT

3RD MCTC
Tumauini, Isabela

THE PUBLIC PROSECUTOR

Counsel for the Plaintiff

GREETINGS:

Please take notice that the undersigned will be submitting the

instant motion for the appreciation and consideration of the
Honorable Court immediately upon receipt hereof.
 MARICION B. CAPILI-GUINGAB

Copy Furnished:

Pros. JOHANS S. GONZAGA

OPP -Ilagan City, Isabela