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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT


First Judicial Region
Branch 59
La Trinidad, Benguet

PEOPLE OF THE PHILIPPINES,


Plaintiff, Criminal Case No.
2015-0085
-versus- For:

AUGUSTUS CAESAR, Reckless


Imprudence
Accused. Resulting to
Homicide

PETITION FOR BAIL


Accused, through the undersigned counsel, unto this
Honorable Court, respectfully states:
1. That accused is currently detained at the La Trinidad
Police Station for the charge of Reckless Imprudence
Resulting to Homicide and has been behind bars since his
arrest on April 20, 2015;
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 the
accused, however, is weak because the records will show
that accused was maliciously implicated in the case through
the sworn statements of May and July who subsequently
recanted their testimonies and confessed, among others,
that they were made to sign the "affidavits of witnesses"
prepared by the police officers of La Trinidad, Police Station.
Thus, being in a state of intoxication they signed the said
affidavits without their free will. (Copies of the Affidavits of
Recantation are hereto attached as Annexes "A" and "B")
4. 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 that accused AUGUSTUS CAESAR be
allowed to post bail for his temporary liberty pending trial of
the criminal charge against him in such amount as this
Honorable Court may fix.
Other just and equitable reliefs are likewise prayed for.
La Trinidad, Benguet, Philippines, this 21st day of May,
2015.
Dakila Del Campo-Domondon
Counsel for the Defendant
No. 17 Karunungan Bldg.
Legarda Rd., Baguio City
Tel. No. 442-2132
Roll of Attorneys No. 37217, 05-21-08
PTR No. 12343/ 01-31-15/Baguio City
IBP Lifetime Membership No. 910/04-23-08/Baguio City
IBP Baguio-Benguet Chapter
MCLE Compliance No. 9876/05-20-2013
Serial No. Of Commission 322-662-01

NOTICE OF HEARING

THE BRANCH CLERK OF COURT


Regional Trial Court
La Trinidad, Benguet, Branch 59

Please submit the foregoing Motion to the Court for its


consideration and approval immediately upon receipt hereof.

Please take notice that counsel has requested to be


heard on Monday, 25 April 2015 at 8:30 in the morning.

Dakila Del Campo-Domondon


Counsel for the Accused

Proof of Personal Service

Copy furnished through personal service:

Prosecutor William T. Bacoling


Provincial Prosecutors Office, Benguet

Atty. James Fernandez


Chan-Fernandez-Tangkia Law Office
Rm. 3, UOB Bldg., Gen. Luna Rd., Baguio City