REPUBLIC OF THE PHILIPPINES

FOURTH JUDICIAL REGION

MUNICIPAL TRIAL COURT IN CITIES
DASMARIAS CITY

PEOPLE OF THE PHILIPPINES,

Plaintiff,

NPS DOCKET NO:

NPSIV-INQ/INV 17H-588
FOR: Alleged Violation of RA
9165 Sec. 11 & 5 in Rel to Sec
21
-versus-

SARAH JANE CINCO Y TORGA and

JAMES BUCOG Y CALABDAN,
Accused.
x- - - - - - - - - - - - - - - - - - - - - - - - - - - - - x

PETITION FOR BAIL

COMES NOW the accused SARAH JANE CINCO Y TORGA and

JAMES BUCOG Y CALABDAN, in the above-entitled case respectfully
states: That----

1. The accused is in custody for alleged commission of Violation

of RA 9165 Sec. 11 & 5 in Rel to Sec 21;

2. Said accused is now detained at the BJMP, Burol II,

Dasmarias, Cavite;

3. Under the constitution and by the statute, every person

charged with an offense including capital offense and other offenses
considered as heinous crimes is entitled to bail, as a matter of right
before conviction. The only exception is in the case of a capital offense
when the evidence of guilt is strong, in which the case there is no right to
bail;

4. The burden of showing that evidence of guilt is strong is on

the prosecution, and unless this fact is satisfactorily shown, the accused
may be bailed at the courts discretion.

1
 WHEREFORE, upon prior notice and hearing, it is respectfully
prayed that accused be admitted to bail in such amount as this
Honorable Court may fix.

22 August 2017, Dasmarias, Cavite

SARAH JANE CINCO Y TORGA JAMES BUCOG Y CALABDAN

Accused-Movant Accused-Movant

COPY FURNISHED:

PO1 PHILIP JOHN BANAAG and

PO1 ARMAEJAEL PEREA
Dasmarinas City Police Station
Malihan St., Zone 4, Dasmarias City, Cavite

OFFICE OF THE CITY PROSECUTOR

Province of Cavite
City of Dasmarias