Republic of the Philippines

National Capital Judicial Region

REGIONAL TRIAL COURT
Branch 255
Las Piñas City

PEOPLE OF THE PHILIPPINES,

Plaintiff

versus Crim. Case No.

For: Murder

JOSE REYES,

Accused.

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PETITION FOR BAIL

COMES NOW, the accused, through the undersigned counsel and unto his Honorable Court,
most respectfully avers:

1. That a corresponding criminal Information was filed before this Honorable Court for Murder,
without any recommendation for bail;

2. That the evidence of guilt submitted against the accused is not strong, and as such he is
entitled to bail under the pertinent provision of the Constitution and under the Rules on
Criminal Procedure;

3. That accused through counsel, most respectfully move that he be allowed to post bail for
his temporary liberty;

PRAYER

WHEREFORE, in the interest of justice and to comply with the constitutional right to bail, it is
most respectfully prayed of for Honorable Court that an Order be issued allowing the accused to post
bail for his temporary liberty based on the above reasons.

Such other relief and remedies as may be deemed just and equitable under the premises are
likewise prayed for.

Manila, 16 January 2006

ROJAS SALINAS TAN AND ONEZA LAW OFFICE
Counsel for the Accused
Suite 506 Santiago Building
Taft Avenue, Manila
By:
FERDINAND A. TAN
IBP No. 610083/2-5-2005/Mla.
PTR No. 3114/5-24-05/Mla.
Roll No.38488

NOTICE OF HEARING
1. THE HON. TRIAL PROSECUTOR
2. THE BRANCH CLERK OF COURT
RTC, BR.1, MANILA