REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

National Capital Judicial Region
Quezon City Branch 45

PEOPLE OF THE PHILIPPINES,

Plantiff,

-versus- CRIMINAL CASE NO. V-08-INQ-15B-09999

FOR: MURDER

PEDRO SAN PEDRO

Accused,

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PETITION FOR BAIL

COMES NOW Defendant, PEDRO SAN PEDRO, by the undersigned counsel

and unto this Honorable Court, most respectfully states that:

The Defendant is in custody for the alleged commission of an offense punishable

by Reclusion Perpetua;

No bail has been recommended for his temporary release, on the assumption that
the evidence of guilt is strong;

The burden of showing that evidence of guilt is strong is on the prosecution, and
unless this fact is satisfactorily shown, the defendant is entitled to bail as a matter of
right.

PRAYER

WHEREFORE, upon prior notice and hearing, it is respectfully prayed that the
Defendant PEDRO SAN PEDRO be admitted to bail in such amount as this Honorable
Court may fix.

Quezon City, Philippines, 10, April 2017.

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RESPECTFULLY SUBMITTED:

DE LEON ARZAGA MENDOZA ORTEGA (DAMO)

LAW OFFICES
Counsel for Accused PEDRO SAN PEDRO
1st Flr. N. Sangalang Bldg.
C. Tirona St., Batangas City

By:

JOEL ARZAGA
Roll No. 43030
IBP No. 873272 Dec 28, 2012
PTR No. 1833670 Jan. 2, 2013 Quezon City
MCLE Exemption No. III-000657
December 16, 2009

The Branch Clerk of Court

Regional Trial Court
Branch 45

MINDA CANTON
Office of the City Prosecutor
Quezon City

GREETINGS:

Please be notified that the foregoing Petition for Bail will be submitted by the
undersigned on April 21 14, 2017 at 2:00 oclock in the afternoon, or as soon thereafter
as counsel and matter may be heard.

April 8, 2017.

JOEL ARZAGA

Copy furnished:
MINDA CANTON
Office of the City Prosecutor
Quezon City

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