Republic of the Philippines

Twelfth Judicial Region

REGIONAL TRIAL COURT
Branch 1
Iligan City

PEOPLE OF THE PHILIPPINES,

Plaintiff,
Criminal Case No. 345
- versus -
For: The Crime of
Homicide

TOM JERRY,
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 Iligan City Jail for the charge
of the crime of homicide and has been behind bars since his arrest on
January 22, 2019;

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 UPIN IPIN and DEE DEXTER 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 TOM JERRY 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.

24 January 2019
City of Iligan.

ATTY. SITTIE RAINNIE BAUD

Counsel for the Accused

NOTICE OF HEARING

THE BRANCH CLERK OF COURT

Regional Trial Court, Branch 1
Iligan City

Greetings!

Please submit the foregoing petition to the Honorable Court on

January 29, 2019 at 8:30 in the morning for its favorable consideration
and approval.

ATTY. SITTIE RAINNIE BAUD

Copy furnished by personal service:

PROSECUTOR NURUL IZZAH HAMED

Office of the City Prosecutor, Iligan City

ATTY. MOHAMAD KALID

Private Prosecutor
3423 Aguinaldo Street, Iligan City