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 asAnnexes "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 thecriminal
charge against him.

Other just and equitable reliefs are likewise prayed for.

Respectfully submitted.

15 August 2013
City of Makati.

A
TTY. VX YZ
Cou
nsel 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