Republic of the Philippines

First Judicial Region

REGIONAL TRIAL COURT
Branch 1
La Trinidad, Benguet

PEOPLE OF THE PHILIPPINES,

Plaintiff,

- versus - Criminal Case No. 12345

for
Murder
JUAN DELA CRUZ

Accused.

x ---------------------------------------- x

PETITION FOR BAIL

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

respectfully states:

1. That accused is currently detained at the Benguet Provincial Jail for the
charge of Murder and has been behind bars since his arrest on April 1, 2017;

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 direct evidence that will point to the accused to have committed the
charges against him. The records will show that accused was maliciously
implicated in the case through the sworn statements of Pedro and Petra 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 JUAN DELA CRUZ 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 2016
La Trinidad, Benguet.

ATTY. VX YZ
Counsel for the Accused

NOTICE OF HEARING

THE BRANCH CLERK OF COURT

Regional Trial Court, Branch 1
La Trinidad, Benguet

Greetings!

Please submit the foregoing motion to the Honorable Court on April 15, 2017
at 8:30 in the morning for its favorable consideration and approval.

VX YZ
Copy furnished by personal service:

PROSECUTOR WX YZ

Office of the Provincial Prosecutor, La Trinidad, Benguet

ATTY. AB CD
Private Prosecutor
Balisong Building Assumption Road, Baguio City