Republic of the Philippines

REGIONAL TRIAL COURT

________ Judicial Region
Branch ____
Tuguegarao City, Cagayan

PEOPLE OF THE PHILIPPINES, CR. CASE NO. _____

Plaintiff,

---versus---- ---for---

_______________________ “VIOLATION OF RA 9165”

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 Bureau of

Jail Management and Penology for the charge
of Violation of RA 9165 and has been behind bars since
his arrest;

2. That no bail has been recommended for his temporary

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

3. That the burden of showing that evidence of guilt is

strong rest upon the prosecution, and unless this fact
is satisfactorily shown, the defendant is entitled to
bail as a matter of right;

WHEREFORE, it is most respectfully prayed of

this Honorable Court that accused
____________________________ 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.

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 ________________________; Tuguegarao City,
Cagayan.

BY:

ATTY. ___________________
Roll No. ________
PTR No. __________/____-___-___/______________
IBP No. _____________/__-__-___/________________
MCLE Compliance No. __________
Issued on _______________________

NOTICE OF HEARING

PROVINCIAL PROSECUTION’S OFFICE

_____________________

CLERK OF COURT
Regional Trial Court
Branch ___
___________________________

MA’AM/SIR:

Greetings!

Please take notice that on ________________ at

___________ o’clock in the morning or upon the
approval of the Honorable Court the instant Petition
shall be heard.

Thank you.

ATTY. ___________________________

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 Copy furnished:

PROVINCIAL PROSECUTION’S OFFICE

_____________________

CLERK OF COURT
Regional Trial Court
Branch ___
___________________________

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;

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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 theAffidavits 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
C
ounsel 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

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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