Republic of the Philippines

Fourth Judicial Region

FAMILY COURT
Branch 5, Trece Martires City
Fc1tm0005@judiciary.gov.ph
0923-482-4559

PEOPLE OF THE PHILIPPINES,

Plaintiff,
Criminal Case No. TMCR – 1311-19
versus For: Rape under par.2 Art. 226-A
of the RPC (Sexual assault)
RANCHELLE ALVAREZ BAYAS,
Accused.
x ---------------------------------------- x
PEOPLE OF THE PHILIPPINES,
Plaintiff, Criminal Case No. TMCR – 1312-19
For: Rape under par.2 Art. 226-A
of the RPC (Sexual assault)
versus
AAA1
Accused.
x ---------------------------------------- x
PEOPLE OF THE PHILIPPINES,
Plaintiff, Criminal Case No. TMCR – 1313-19
For: Rape under par.2 Art. 226-A
of the RPC (Sexual assault)
versus

SHAMIR MELCHOR CABATBAT

a.k.a SHAMIR
x ---------------------------------------- x
PEOPLE OF THE PHILIPPINES,
Plaintiff, Criminal Case No. TMCR – 1314-19
For: Rape under par.2 Art. 226-A
of the RPC (Sexual assault)
versus

JAMES VENTURINA COMPRIDO

Accused
x ---------------------------------------- x
PEOPLE OF THE PHILIPPINES,
Plaintiff, Criminal Case No. TMCR – 1315-19
For: Rape under par.2 Art. 226-A
of the RPC (Sexual assault)
versus

EUGENE JOSEPH PORTO y SUMAGUI,

a.k.a EUGENE
Accused
x ---------------------------------------- x

MOTION FOR BAIL

 THE ACCUSED, by counsel, respectfully moves to be allowed bail
on the ground Criminal Case No. TMCR – 1311-19 For Rape under par.2
Art. 226-A of the RPC (Sexual assault);

1. Rule 114, Section 4 of the rules of court provides;

Section 4. Bail, a matter of right; exception. — All persons in

custody shall be admitted to bail as a matter of right, with
sufficient sureties, or released on recognize as prescribed by
law or this Rule (a) before or after conviction by the
Metropolitan Trial Court, Municipal Trial Court, Municipal
Trial Court in Cities, or Municipal Circuit Trial Court, and (b)
before conviction by the Regional Trial Court of an offense
not punishable by death, reclusion perpetua, or life
imprisonment. (4a)

2. Thus the accused is entitled to bail as a matter of right.

WHEREFORE, it is respectfully prayed that the accused be

granted: (1) a bail hearing, during which the prosecution should be
directed to present its evidence to show the strength of its evidence of the
accused’s guilt, and (2) thereafter, grant the accused reasonable bail.

Other just and equitable reliefs are also prayed for.

Silang, Cavite for the City of TRECE MARTIRES; OCTOBER 12, 2020

ATTY. IRINEO A. ANARNA

(Counsel for the Accused)
No. 4 Madlansacay St. Brgy. Poblacion II,
Silang, Cavite

GREETINGS:

Due to the urgency of the foregoing motion, please

submit the foregoing motion for bail for consideration and
approval of the Honorable Court immediately upon receipt
hereof. Thank you.

Copy Furnished:

Pros. Gee B. Rosanes

Trial Prosecutor
 Lourie jane A Braga
Private Complainant