Republic of the Philippines

National Capital Judicial Region

REGIONAL TRIAL COURT
Branch 147
Makati City
PEOPLE OF THE PHILIPPINES,
Plaintiff,
Crim Case No. 12345
- versus for
Frustrated
Murder
AKU SADO,
Accused.
x - - - - - - - - - - - - - - - - - - - - -x

PETITION FOR BAIL

Accused, through the undersigned counsel, unto this
Honorable Court, respectfully states:
1. That accused is currently detained at the Makati City Jail for
the charge of Frustrated Murder and has been behind bars since
his arrest on August 1, 2013;
2. That no bail has been recommended for his temporary release
on the assumption that the evidence of guilt is strong;
3. That the prosecution's evidence of guilt against accused,
however, is weak as there is no direct evidence that will point to
the accused to have committed the the charges against him. The
records will show that accused was malicious implicated in the
case through the sworn statements of SINU NGALING and BULA
AN who subsequently recanted their testimonies and confessed,

among others, that they were made to sign the "affidavits of

witnesses" against their will. (copies of the Affidavits of
Recantation are hereto attached as Annexes "A" and "B")
4. That there is no other physical or documentary evidence to
show that accused is guilty of the crime charged;.
5. That the burden of showing that evidence of guilt is strong
is on the prosecution, and since this fact is not satisfactorily
shown, accused is entitled to bail as a matter of right during the
pendency of the criminal case.
WHEREFORE, upon prior notice and hearing, it is
respectfully prayed of this Honorable Court that accused AKU
SADO be allowed to post bail for his temporary liberty pending
trial of the criminal charge against him.
Other just and equitable reliefs are likewise prayed for.
Respectfully submitted.
15 August 2013
City of Makati.
ATTY. VX YZ
Counsel for the Accused
NOTICE OF HEARING
THE BRANCH CLERK OF COURT
Regional Trial Court, Branch 147
Makati City
Greetings!
Please submit the foregoing motion to the Honorable Court on
August 27, 2013 at 8:30 in the morning for its favorable
consideration and approval.

VX YZ
Copy furnished by personal service:
PROSECUTOR WX YZ
Office of the City Prosecutor, Makati City
ATTY. AB CD
Private Prosecutor
2233 Zamora Street, Pasay City