Republic of the Philippines
National Capital Judicial Region
REGIONAL TRIAL COURT
Branch 11
Manila City
PEOPLE OF THE PHILIPPINES,
Plaintiff,
Crim Case No. 12345
- versus - For: 4 counts of Rape with homicide
Kiko
Accused.
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PETITION FOR BAIL
Accused, through the undersigned counsel, unto this Honorable Court,
respectfully states:
1. That accused is currently detained at the Manila City Jail for the charges
of four (4) counts of Rape with homicide and has been behind bars since his
arrest on November 24, 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 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 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 Kiko 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.
03 January 2020
City of Manila.
ATTY. ABOGADO ABOGAGA
Counsel for the Accused
NOTICE OF HEARING
THE BRANCH CLERK OF COURT
Regional Trial Court, Branch 147
Manila City
Greetings!
Please submit the foregoing motion to the Honorable Court on January 6,
2020 at 8:30 in the morning for its favorable consideration and approval.
ATTY. AOGADO
ABOGAGA
Copy furnished by personal service:
PROSECUTOR ATTY. ROMINA MONDRAGON
Office of the City Prosecutor, Manila City
