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 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 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 HonorableCourt 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