Scribd Logo
Upload

Welcome to Scribd!

  • 100 views

    Petition To Bail

    Uploaded by

    Kang Aira
    Atty. Lourdes Santos

    Copyright:

    © All Rights Reserved
    Download as RTF, PDF, TXT or read online from Scribd

    Petition To Bail

    Uploaded by

    Kang Aira
    100 views4 pages
    Atty. Lourdes Santos

    Original Title

    Petition to bail

    Copyright

    © © All Rights Reserved

    Available Formats

    RTF, PDF, TXT or read online from Scribd

    Did you find this document useful?

    Is this content inappropriate?

    Atty. Lourdes Santos

    Copyright:

    © All Rights Reserved
    Download as RTF, PDF, TXT or read online from Scribd
    Download as rtf, pdf, or txt
    100 views4 pages

    Petition To Bail

    Uploaded by

    Kang Aira
    Atty. Lourdes Santos

    Copyright:

    © All Rights Reserved
    Download as RTF, PDF, TXT or read online from Scribd
    Download as rtf, pdf, or txt
    of 4

    Republic of the Philippines

    National Capital Judicial Region

    REGIONAL TRIAL COURT

    Branch 11

    Manila City

    PEOPLE OF THE PHILIPPINES,

    Plaintiff,

    Crim Case No. 12345

    - versus - For: 4 counts of Rape with homicide

    Kiko

    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 Manila City Jail for the charges
    of four (4) counts of Rape with homicide and has been behind bars since his
    arrest on November 24, 2019;

    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 Kiko 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.

    03 January 2020

    City of Manila.

    ATTY. ABOGADO ABOGAGA

    Counsel for the Accused

    NOTICE OF HEARING

    THE BRANCH CLERK OF COURT

    Regional Trial Court, Branch 147

    Manila City

    Greetings!

    Please submit the foregoing motion to the Honorable Court on January 6,


    2020 at 8:30 in the morning for its favorable consideration and approval.
    ATTY. AOGADO
    ABOGAGA

    Copy furnished by personal service:

    PROSECUTOR ATTY. ROMINA MONDRAGON

    Office of the City Prosecutor, Manila City

    You might also like