REPUBLIC OF THE PHILIPPINES

SIXTH JUDICIAL REGION

BRANCH ____
REGIONAL TRIAL COURT
____________

PEOPLE OF THE PHILIPPINES,

-versus-
CRIMINAL CASE NO.
BOGART UNOS 18 – x x x x
Accused.
x------------------------------------------x

PETITION TO FIX BAIL

COME NOW, Accused through the undersigned counsel and

unto this Honorable Court most respectfully state that:

1. Herein ACCUSED was charged with Violation of

Sections 5 and 11 of Art. II, RA 9165 now pending
before this Honorable Court;

2. Both Accused were detained at City District Jail and No

Bail Recommended for their Temporary Liberty for the
3. Accused was illegally arrested and no items were
recovered from them;

4. The truth was On February 4, 2018 two armed men in

civilian clothes entered the boarding house. The
accused was instructed to sit and wait in the living
room. After which, they were handcuffed and brought
to Police station, copy of the Police Blotter dated
February 28, 2018 is hereto attached and marked as
Annex “A”;

5. Based on the Affidavits of PO3 Dino Paolo and PO2 Gat

Maro who were the Arresting Officers at the time of the
incident, nowhere were it ever stated vividly how the
alleged prohibited items were recovered and how the
search was conducted;

6. The arresting officers merely alleged that they

conducted a buy bust operation but failed to describe
in detail how it was conducted, thereby making the
alleged participation of the Accused in the commission
of the said offense far from probable;

7. Based on the foregoing pieces of evidence, there is no

strength on the probability of herein Accused
committing the unlawful acts mentioned above;

8. Consequently, the evidence of guilt based on these

pieces of evidence is not strong and this Honorable
 9. Likewise, the possibility of escape on the part of the
Accused is nil because they have no record
whatsoever of being escapees;

10. Herein Accused promise and bind themselves to

appear and attend every hearing of the above
entitled case if they are granted to post bail and
allowed temporary liberty.

WHEREFORE, premises considered it is most respectfully

prayed upon this Honorable Court that, after hearing the same,
this Honorable Court will fix reasonable amount of bail for the
temporary liberty of the Accused. Other remedies that are just
and equitable under the premises are likewise prayed for.

RESPECTFULLY SUBMITTED.