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Republic of the Philippines

REGIONAL TRIAL COURT


National Capital Region
Branch ___
Makati City

PEOPLE OF THE
PHILIPPINES,
Plaintiff

-versus- Criminal Case No. ________

JUAN DELA CRUZ, For: Illegal Possession of


Dangerous Drugs
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 Bureau of Jail


Management and Penology for the charge of Violation of R.A. 9165 and has
been behind bars since his arrest last July 31, 2018;

2. That no bail has been recommended for his temporary release on


the assumption that the evidence of guilt is strong;

3. That the burden of showing that evidence of guilt is strong rest


upon the prosecution, and unless this fact is satisfactorily shown, the
defendant is entitled to bail as a matter of right;

WHEREFORE, it is most respectfully prayed of this Honorable Court


that accused Juan Dela Cruz 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.

Makati City; August 14, 2018.

ANNEX L Page 1 of 2
Atty. Regina Coeli Cigaral
Counsel for the Defendant
Bucu & Associates
PTR No. 11231092
IBP No. 1930211
Roll No. 1930211
Ateneo Professional Schools,
Rockwell Drive, Makati City, Philippines

NOTICE OF HEARING

THE BRANCH CLERK OF COURT


Regional Trial Court, Branch ___
Makati City

Greetings!

Please submit the foregoing to the Honorable Court on August 15,


2018 at 8:30 in the morning for its favorable consideration and approval.

Thank you.

Atty. Regina Coeli Cigaral


Counsel for the Defendant
Bucu & Associates
PTR No. 11231092
IBP No. 1930211
Roll No. 1930211
Ateneo Professional Schools,
Rockwell Drive, Makati City, Philippines

Copy furnished:

Prosecutor Raymond Lim


Office of the City Prosecutor, Makati City

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