Republic of the Philippines

REGIONAL TRIAL COURT

Ninth Judicial Region
Branch 14
Zamboanga City

PEOPLE OF THE PHILIPPINES, Criminal Case No. 35820

Plaintiff,
- for -
- versus –

“SWEET”, Violation of Sec. 5

Accused. Art. II of R.A. 9165
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PETITION FOR BAIL

     
      Accused, through the undersigned counsel, unto this Honorable
Court, respectfully states:

1. That accused is currently detained at the Zamboanga City Jail for the charge
of Violation of Sections 5 and 11 of Article II of Republic Act 9165 and Section 28 (a)
in relation to Section (e) under Criminal Case Numbers 35820, 35821, and 35823
and has been behind bars since his arrest on April 15, 2017;

2. That no bail has been recommended for his temporary release for violation
of Section 5 Article II of the “Comprehensive Dangerous Drugs Act of 2002” of
Republic Act No. 9165 on the assumption that the evidence of guilt is strong;

3. That the prosecution's evidence of guilt against accused, however, is weak

as it will be proven in the summary hearing, because the accused was actually
illegally arrested without a warrant. The allegation of buy-bust is merely a
fabrication of the police officers as will be proven by the prosecution and the
accused evidence during the summary hearing for the petition of bail;

4. 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 SWEET, 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 this 7th day of July, 2017 in the City of Zamboanga.

1
 LIONG SEDILLO TORREMONIA† & DIESTO
Counsel for the Accused
Block E-43 & 44-E, Plaza del Pilar, Sta. Barbara Road,
Brgy. Zone IV, beside Hall of Justice, Zamboanga City
Email: lstdlawfirm@gmail.com
Tel No. (062) 926 – 0995

By:

NOTICE OF HEARING

THE BRANCH CLERK OF COURT

Regional Trial Court, Branch 14
Zamboanga City
    
Greetings:

Please schedule the summary hearing of the instant Petition at the

convenient calendar of the Honorable Court, for its resolution and approval.

Copy furnished:

Office of the City Prosecutor ________________

Hall of Justice, Zamboanga City