Republic of the Philippines

REGIONAL TRIAL COURT

11th Judicial Region
Branch 19
Digos City

OFFICE OF THE EXECUTIVE JUDGE

WARIOLE G. ANDO, NPS-XI-04-INQ-181-00255
Complainant,

-versus- FOR: RECKLESS IMPRUDENCE

RESULTING TO HOMICIDE AND
DAMAGE TO PROPERTY

ALEX H. LARRACOCHEA,
Respondent,
X = = = = = = = = = = = = = = = = =/

UERGENT PETITION TO ADMIT BAIL WHILE PENDING

PRELIMINARY INVESTIGATION

COMES NOW, respondent ALEX H. LARRACOCHEA, assisted by

the undersigned counsel, unto this Honorable Court most respectfully state;

That said respondent is facing charge for violation of Reckless

Imprudence Resulting to Homicide and Damage to Property now pending
preliminary investigation at the Office of the Provincial Prosecutor of Davao
del Sur;

That respondent is very desirous to be out of bail in order to enjoy

temporary liberty pending the results of the preliminary investigation;

That this petition is filed in accordance with Rule 114, Sec. 17, Par (c)
of the Revised Rules of Criminal Procedure which provides that:

“any person in custody who is NOT yet charged in Court may apply
for bail with any Court in the Province, City or Municipality where he is held.”

That a willing bondsman is ready to put up a bail bond of the above-

named respondent.

WHEREFORE, in view of the foregoing premises, it is most

respectfully prayed that this PETITION be granted for the reasons
aforestated.

Other reliefs, just and equitable are likewise being prayed for.

Digos City, Davao del Sur, Philippines, December 21, 2018.

ALEX H. LARRACOCHEA
Respondent/Petitioner

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Assisted by:

ATTY. CARLO MARTIN D. MARTEL

Counsel for the Respondent
Roll of Attorney’s No. 67186
IBP Number: 1082743 ; 01/04/18
PTR Number: 7110613 ; 01/03/18
MCLE Compliance No.: (NEW LAWYER) / May 24, 2017
WONG & MARTEL LAW OFFICES, 2/F Rural Bank of Digos Building,
Rizal Avenue, Digos City, Davao del Sur

NOTICE OF SUBMISSION

Clerk of Court
Office of the Clerk of Court
Digos City, Davao del Sur

G R E E T I N G S!

Please submit the foregoing Urgent Petition To Admit Bail While

Pending Preliminary Investigation for the consideration and approval of this
Honorable Office, upon receipt thereof, without further oral argument.

ALEX H. LARRACOCHEA
Respondent/Petitioner

Copy furnished:

- Provincial Prosecutor’s Office, Digos City, Davao del Sur

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