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Republic of the Philippines

Regional Trial Court


11th Judicial Region
Branch __, Digos City

THE PEOPLE OF THE


PHILIPPINES,
Complainant,
Criminal Case No. 001234
- versus – For: R.A. 9165

JOHN LLOYD ADARNA


Accused.
X- - - - - - - - - - - - - - - x

PETITION FOR BAIL

The Accused, through the undersigned counsel, and unto


this Honorable Court, respectfully files this Petition by
stating THAT:

1. Accused is currently detained at Digos City Jail for


the charge of Rape and has been behind bars since his
arrest on October 16, 2017;

2. No bail has been recommended for his temporary


release on the assumption that the evidence of guilt is
strong;

3. 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 charges against
him. The accused was not in possession of the alleged one
piece small heat sealed transparent plastic sachet of shabu
weighing 0.365 grams at the time of the apprehension of
the said illegal drugs;

4. The records will show that accused was malicious


implicated in the case through the information filed by CITY
PROSECUTORTRIZIA JANELLI B. PAULINO. A copy of
the saidinformation is herein attached as Annex “A” and the
same is made an integral part of this petition;

5. There is no other genuine physical or documentary


evidence to show that accused is guilty of the crimecharged;

6. 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.

PRAYER

WHEREFORE, upon prior notice and hearing, it is most


respectfully prayed of this Honorable Court that Accused
JOHN LLYOD ADARNAbe 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, this 7th day of


December 2017, at the city of Digos, Davao del Sur.

PRACTICE COURT II DIAZ GROUP


CorJesu College, College of Law, Digos City
Tel. No.: (xx)xxx-xxx/Cell No.: +63 927 317 8522
Email address: sdemrev@gmail.com

By:
ATTY. DEMREV C. SALAZAR
Notary Public Until December 31, 2017
Roll No. XXXXX; TIN: XXX-XXX- XXX
BP OR No. XXXXXXX; 12-27- 16
(CY 2018) PTR No. XXXXXXX; 1-04- 17;
City of Digos
Doc. No. ____;
Page No. ____;
Book No. ____;
Series of 2017.

NOTICE OF HEARING
The Clerk of the Office
Regional Trial Court
Digos City, Davao del Sur

Please submit the foregoing Motion for the approval of


theHonorable Court on December 8, 2017 at 8:30 in the
morning for its favourable consideration and approval.

ATTY. DEMREV C. SALAZAR

Copy Furnished:

PRACTICE COURT II CALATRAVA GROUP


CorJesu College of Law Digos City
Date : _______________
RR : ________________

Explanation of service and filing by registered mail: A


copy of this motion was served and filed by registered mail
due to distance constraints.