Republic of the Philippines
MUNICIPAL TRIAL COURT
11th Judicial Region
Branch ____, Davao City
PEOPLE OF THE PHILIPPINES
NPS DOCKET NO. XI-02-INQ-19-D-1254
- versus -
FOR: P.D. 1602
JERRY A. GARCIA
JELLY H. LUCHAVEZ
MARILYN D. SEVILLA
Respondents(Detained)
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PETITION TO POST BAIL
Respondents JELLY H. LUCHAVEZ and MARILYN D. SEVILLA, assisted by the Public
Attorney’s Office for this purpose only, through the undersigned, and unto this Honorable Court,
most respectfully avers, THAT:
1. All the herein accused, JERRY A. GARCIA, JELLY H. LUCHAVEZ and MARILYN D.
SEVILLA, had undergone inquest proceedings on April 26, 2019 before the Prosecutor
Lao of the City Prosecutor’s Office of Davao for the above alleged offense;
2. The offense to which they are being charged of is bailable in the amount of P30,000.00
each;
3. JERRY A. GARCIA, JELLY H. LUCHAVEZ and MARILYN D. SEVILLA are presently
detained at the Police Station 11, Baguio District, Davao City;
4. Pending Resolution of the complaint filed against them, JELLY H. LUCHAVEZ and
MARILYN D. SEVILLA desire to exercise their right to bail under Sec, 4, Rule 114 of the
Rules of Court, hence, this Petition.
WHEREFORE, it is most respectfully prayed of the Honorable Court that respondents JELLY
H. LUCHAVEZ and MARILYN D. SEVILLA be allowed to post bail in the amount of P30,000.00 each.
Davao City, Philippines, April 29, 2019.
JELLY H. LUCHAVEZ
Respondent
MARILYN D. SEVILLA
Respondent
Assisted by:
PUBLIC ATTORNEY’S OFFICE
Regional Office XI, Davao City
By:
KRISTYN JEAN R. LAO-LAGUINDAM
1
Public Attorney II
VERIFICATION
Republic of the Philippines)
In the City of Davao. . . . . .)S.S.
x - - - - - - - - - - - - - - - - - -X
We, JELLY H. LUCHAVEZ and MARILYN D. SEVILLA, of legal ages, Filipino, and a residents
of Purok 3-B, Barangay Malagos, Baguio District, Davao City, respectively, under oath, depose
and say that:
1. We are the respondent in the above-entitled case;
2. We have caused the preparation of this petition;
3. We have read the same and that all the allegations contained therein are true and
correct of their own personal knowledge.
IN WITNESS WHEREOF, I have hereunto set my hand this 29th day of April 2019, at Davao
City, Philippines.
JELLY H. LUCHAVEZ
Respondent
MARILYN D. SEVILLA
Respondent
SUBSCRIBED AND SWORN to before me this 29th day of April 2019, at Davao City,
Philippines.
KRISTYN JEAN R. LAO-LAGUINDAM
Public Attorney II
(Pursuant to R.A. 9406)
NOTICE OF SUBMISSION
OCC Clerk of Court
Prosecutor Lao
Greetings:
Please submit the foregoing motion immediately upon receipt hereof for the
consideration and approval of the Honorable Court sans appearance of counsel.
Thank you.
KRISTYN JEAN R. LAO-LAGUINDAM
2
Public Attorney II
Copy furnished:
City Prosecution Office
3