Republic of the Philippines

REGIONAL TRIAL COURT

BRANCH 40
Calapan City

PEOPLE OF THE PHILIPPINES

Plaintiff, CRIMINAL CASE NO. 20-28351

-versus- -for-

JOHN Y. DEPP Violation of Sec 5 & 12 Art. 2 of

Accused, R.A. 9165
x-----------------------------------x

PETITION FOR BAIL

ACCUSED, through the undersigned counsel, unto this Honorable Court,

respectfully states:

1. That accused is currently detained at the Bureau of Jail Management and

Penology for the charge of Violation of RA 9165 and has been behind bars
since his arrest;

2. That no bail has been recommended for his temporary release on the
assumption that the evidence of guilt is strong;

3. That the burden of showing that evidence of guilt is strong rest upon the
prosecution, and unless this fact is satisfactorily shown, the defendant is
entitled to bail as a matter of right;

WHEREFORE, it is most respectfully prayed of this Honorable Court that

accused JOHN Y. DEPP 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.

May 8, 2020, Calapan City, Oriental Mindoro

(Sgd)ATTY. SAI A.
GUTIERREZ
Counsel for the Accused
Roll No. 77790
IBP No. 093459 10-18-19
PTR No. 0556040 01-13-20
MCLE Compliance No.IV-
443584
Issued on December 12, 2019
 143 Forever St., Calapan City
Tel No. 288-2014
NOTICE OF HEARING

PROVINCIAL PROSECUTION’S OFFICE

CLERK OF COURT
Regional Trial Court
Branch 40
HON. CEFELINE R. GOCO

MA’AM:

Greetings!

Please take notice that on May 21, 2020 at 8:30 o’clock in the morning or
upon the approval of the Honorable Court the instant Petition shall be heard.

Thank you.

ATTY. SAI A. GUTIERREZ

Copy furnished:

PROVINCIAL PROSECUTION’S OFFICE

HON. CEFELINE R. GOCO