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Republic of the Philippines

6th Judicial Region


REGIONAL TRIAL COURT
Branch 57-San Carlos City
PETITION FOR BAIL OF:

Special Proc. No. __________

REYNATO BULFA y Caburnay,


JESSICA PARCON y Magno,
JEROME PARCON y Magno,
JUDITH GENON y Sortigosa,
JOSEPH MAGNO y Carbaquel,
RAYMUNDA SALINAS y Mancao,
RONEL LOQUE y Razon,
JECTOPHER MADERAZO y Catalua,
YOLANDO ESOGAN y Librando,
GEGIE ESOGAN y Paran,
JOEL JUNSAY y Balasoto,
CHRICEMAR GENON Y Sortigosa,
Petitioners
x------------------------------------------x

URGENT PETITION FOR BAIL


COMES NOW, the Petitioners, through the undersigned counsel, unto
this Honorable Court, most respectfully states that:
1. Records of the San Carlos City Police Station shows that in December
4, 2014, on or about 3:30 oclock in the morning, by virtue of a search
warrant issued by Presiding Judge of RTC Branch 49 of Bacolod City,
herein Petitioners were apprehended by the elements of SOG NOPPO
and NOPSC, ANNEX A;
2. That herein Petitioners were immediately placed under the custody of
the San Carlos City PNP where they continued to be detained as of
this filing;
3. That as of the moment, no criminal complaint for alleged violation of
PD 1602 was filed before the Office of the City Prosecutor neither an
Inquest Proceedings was ever conducted. In short, there is no case that
is filed yet before the Office of the City Prosecutor and or the proper
court in connection with the case;
4. The Petitioners are pleading the indulgence of this Honorable Court
for the allowance of BAIL pending the inquest proceedings and filing
of the proper information against the Petitioners in court by the San

Carlos City Prosecutors Office pursuant to Paragraph (c), Section 17


of the Revised Rules on Criminal Procedure which provides:
(c) Any person in custody who is not yet charged in court
may apply for bail with any court in the province, city or
municipality where he is held
5. The Petitioners are heads of their respective families and on account
of the impending landfall of another super typhoon Ruby, they need
to be released immediately to secure their respective families against
the apparent natural calamity;
6. That Petitioners faithfully undertake to submit themselves to the court
or any government authorities whenever their presence is required or
necessary in connection with the instant case;
7. That the instant case is BAILABLE in nature thus Petitioners are
qualified to apply for bail considering that the main purpose for bail is
to guarantee the appearance of the accused at the trial, or whenever so
required by the court (Yap, Jr. vs. CA, 358 SCRA 564);
8. That considering that no information was yet filed by the City
Prosecutors Office of San Carlos City, there is a need for this
Honorable Court to fix the amount of bail bond for each of the
Petitioner on account of the crime by which they were apprehended;
9. That this instant Petition is not intended to delay proceedings of this
case but for reasons above stated particularly for humanitarian
reasons;

PRAYER
WHEREFORE, PREMISES CONSIDERED, it is most respectfully
prayed the following:
1. That the instant Petition be GRANTED and an Order be issued fixing
the bail of the herein Petitioners in accordance with the bail bond
guide pending the filing of the proper Information in Court;
2. Issue an Order directing the Station Commander of San Carlos City
Police Station, San Carlos City, Negros Occidental and/or any
authorities concerned, who are in ACTUAL CUSTODY of the
Petitioners to IMMEDIATELY RELEASE them upon posting of the
bond fixed by this Honorable Court, unless they are detained for some
other legal charge or charges.
Other relief and remedies that are just and proper under the
circumstances are likewise prayed for.

RESPECTFULLY SUBMITTED.
Bacolod City, Philippines, December 4, 2014.

MALUNES, MAMPANG & MONTORO


LAW OFFICE
Counsel for the Petitioners
Room 202, Park Lane Building,
Hilado-Tindalo Ave., Bacolod City
BY:
ARIEL I. MALUNES
IBP Roll No. 51729
IBP No. 929358 - 01/6/14, Bacolod City
PTR No. 625612, 1/15/14- E.B. Magalona, Neg. Occ.
MCLE Compliance No. IV- 0022885
cc.

San Carlos City


PNP
NOTICE OF HEARING

The Clerk of Court


RTC Branch 57, San Carlos City
San Carlos City PNP
Negros Occidental
Greetings!
Due to urgency, kindly set the foregoing petition for bail for the
consideration and approval of this Honorable Court immediately upon receipt
hereof, without oral argument.
Thank you.
ARIEL I. MALUNES