Republic of the Philippines

National Capital Judicial Region

REGIONAL TRIAL COURT
Branch 147
Makati City
PEOPLE OF THE PHILIPPINES,
Plaintiff,
Crim Case No. 12345
- versus -

for
Frustrated Murder

AKU SADO,
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 Makati City Jail for the charge of Frustrated Murder and has
been behind bars since his arrest on August 1, 2013;
2. That no bail has been recommended for his temporary release on the assumption that theevidence of
guilt is strong;
3. That the prosecution's evidence of guilt against accused, however, is weak as there is
nodirect evidence that will point to the accused to have committed the the charges against him. The
records will show that accused was malicious implicated in the case through the sworn statements of
SINU NGALING and BULA AN who subsequently recanted theirtestimonies 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 AKU SADO 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 2013
City of Makati.
ATTY. VX YZ
Counsel for the Accused

NOTICE OF HEARING
THE BRANCH CLERK OF COURT
Regional Trial Court, Branch 147
Makati City
Greetings!
Please submit the foregoing motion to the Honorable Court on August 27, 2013 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 City Prosecutor, Makati City
ATTY. AB CD

Private Prosecutor
2233 Zamora Street, Pasay City