Republic of the Philippines

National Capital Judicial Region

 REGIONAL TRIAL COURT
Branch ___
Makati City

PEOPLE OF THE PHILIPPINES,

                                      Plaintiff,
                                                       
Crim Case No. 12345 
       For: ___________
                - versus -                                                                            
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 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 2019.
          City of Makati.

                                                                                          
                                            
Counsel 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, 2019 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