Republic of the Philippines

National Capital Judicial Region

REGIONAL TRIAL COURT
Branch 003
Manila City

PEOPLE OF THE PHILIPPINES,

Plaintiff,

Crim. Case No. 201

-versus- FOR: Violation of Article 320 of the
Revised Penal Code, as amended by
Presidential Decree 1613

NORA IVANKA BARRIOS,

Accused.
X - - - - - - - - - - - - - - - - - - - - - -/

PETITION FOR BAIL

NORA IVANKA BARRIOS, through the undersigned counsel, unto this
Honorable Court, respectfully states:

1. That accused is currently detained at the Manila City Jail for the charge
of Violation of Article 320 of the Revised Penal Code, as amended by
Presidential Decree 1613 and has been behind bars since her arrest;
2. That no bail has been recommended for her temporary release;
3. That the imposable penalty stated by the Revised Penal Code is
reclusion perpetua;
4. That according to Section 4 of Rule 114 of the Revised Rules on
Criminal Procedure, bail is not a matter of right for an accused charged
with death, reclusion perpetua, or life imprisonment before a
conviction by the RTC;
5. That such provision is not an express prohibition on the grant of bail
to the accused, and merely transforms the grant of bail from being a
matter of right to a matter of judicial discretion;
6. That according to Section 7 and 8 of the same Rule, bail shall be denied
to the accused if evidence of guilt is strong, and the burden of proving
such rests upon the prosecution;
7. That the evidence postured by the prosecution is merely
circumstantial, thus casting doubts on the guilt of the accused;
8. That absent any other proof of the prosecution that the evidence of
guilt is strong, and the lack of the circumstances listed in Section 5 of
Rule 114, there is no obvious and apparent reason to deny the
application for bail;
 WHEREFORE, it is most respectfully prayed of this Honorable Court that
accused NORA IVANKA BARRIOS be allowed to post bail for her temporary
liberty pending trial of the criminal charge against her.

Other just and equitable reliefs are likewise prayed for.

November 4, 2018; Manila City.

ATTY. CALVIN HARDIN

Roll No. 12345
PTR No. 2651863/01-20-2014/
IBP No. _____________/__-__-___/________________
MCLE Compliance No. __________
Issued on _______________________
 NOTICE OF HEARING

OFFICE OF THE CITY PROSECUTOR

Manila City

CLERK OF COURT
Regional Trial Court
Branch 003
Manila City

MA’AM/SIR:

Greetings!

Please take notice that on November 8, 2018 at 8 o’clock in the

morning or upon the approval of the Honorable Court the instant Petition
shall be heard.

Thank you.

ATTY. CALVIN HARDIN

Roll No. 12345
PTR No. 2651863/01-20-2014/
IBP No. _____________/__-__-___/________________
MCLE Compliance No. __________
Issued on _______________________

Copy furnished:

OFFICE OF THE CITY PROSECUTOR

Manila City

CLERK OF COURT
Regional Trial Court
Branch 003
Manila City