Republic of the Philippines National Capital Judicial Region REGIONAL TRIAL COURT Branch 147 Makati City PEOPLE

OF Plaintiff, Crim Case No. 12345 for Frustrated Murder AKU SADO, Accused. x - - - - - - - - - - - - - - - - - - - - -x versus THE PHILIPPINES,

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 2013 City of Makati. ATTY. VX YZ 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, 2013 at 8:30 in the morning for its favorable consideration and approval.

VX YZ Copy PROSECUTOR WX Office of the City Prosecutor, Makati City ATTY. AB CD furnished by personal service: YZ

Private Prosecutor 2233 Zamora Street, Pasay City