Republic of the Philippines

____________ Judicial Region

________________ TRIAL COURT

Branch _____, _____________, _____________

PETITION FOR BAIL

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

1. That accused is currently detained at the _______________________________ for the charge of __________________________ and has been behind bars since his arrest on _______________ _______, _______;

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 _______________________________ 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 2013

City of Makati.

ATTY. _______________________________

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 ___________, 20____ at ____:___ in the morning/afternoon for its favorable consideration and approval.

_______________________________

Copy furnished by personal service:

PROSECUTOR _______________________________

Office of the City Prosecutor, Makati City

ATTY. _______________________________

Private Prosecutor

2233 Zamora Street, Pasay City