REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

National Capital Judicial Region
Branch 1,
Manila

PEOPLE OF THE PHILIPPINES,

Plaintiff,

Criminal Case No. ______

For: Murder
-versus-

JUAN DELA CRUZ,

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

MOTION FOR BAIL

Defendant in the above-entitled case, thru counsel, unto this Honorable Court,
respectfully states:

1. That the defendant is in custody for the alleged commission of a capital offense;
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 is on the prosecution, and
unless this fact is satisfactorily shown, the defendant may be bailed at the court’s
discretion.

WHEREFORE, upon prior notice and hearing, it is respectfully prayed that the defendant
by admitted to ball in such amount as this Honorable Court may fix.

City of Manila, June 15, 2016.

ATTY. JUANICO FRANCISCCO

Counsel for Defendant
Unit 1, X Building, Recto, Manila
IBP No. 123456; 01/10/10 – Manila
PTR No. 1234567; 01/10/10 – Manila
Roll No. 12345; 5/05/05
MCLE No. I – 001234; 9/09/09
MCLE No. II – 115678; 9/09/09

REQUEST FOR & NOTICE OF HEARING

Copy furnished:
Name and Address of Counsel of the Other Parties

PROOF OF SERVICE
EXPLANATION (if served by registered mail)