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Republic of the Philippines

National Capital Judicial Region


REGIONAL TRIAL COURT
Branch 147
Makati City

PEOPLE OF THE PHILIPPINES,


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

PETITION FOR BAIL

Accused, through the undersigned counsel, unto this Honorable


Court, respectfullystates:

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 directevidence 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
MOTION TO REDUCE BAIL
Accused, through counsel, by way of a special appearance solely for this
purpose, respectfully alleges:

1.That the accused has been charged with _____________ and that the bail
for his provisional release has been set at P_____________;

2. That the accused is a poor fellow of very limited means such that it is
impossible for him to pay the full amount of his bond and is therefore
constrained to request for a reduction of the amount of bail;

3. That it would be advantageous to everyone if he be given temporary


liberty thereby allowing him to continue with his gainful employment and as
head of the family with _____________ dependents;

4. As such, accused appeals to the mercy and compassion of this Honorable


Court and respectfully requests that his bail be reduced to P_____________.

5.That this motion for reduction of bail is being filed without prejudice to any
other remedy which may be available to the accused and that the accused
expressly reserves the right to question the legality of the issuance of the
search warrant or his warrantless arrest if the circumstances would so
warrant.

WHEREFORE, accused respectfully prays that his bail be reduced to


P_____________.

Other relief just and equitable are likewise prayed for.

_____________, Philippines, __Date__.

(COUNSEL)

(NOTICE OF HEARING)

(EXPLANATION)

COPY FURNISHED:

OPPOSING COUNSEL