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REPUBLIC OF THE PHILIPPINES

National Capital Judicial Region


METROPOLITAN TRIAL COURT
Branch 00, Caloocan city
(SATURDAY COURT)

PEOPLE OF THE PHILIPPINES,

CRIM. CASE No. 00000


-versus- FOR: Violation of ______

IMELDA REMEDIOS VISITACIÓN


ROMUÁLDEZ-MARCOS,
Accused.
x- - - - - - - - - - - - - - - - - - - - - - - -x

URGENT MOTION
TO REVIVE THE CASE AND TO POST BAIL

Accused, unto this Honorable Court, respectfully states:

1. That the accused has been charged with violation of


_________________, as amended, for
___________________.
2. That the bail for her provisional release has been fixed at
FOUR THOUSAND PESOS (P4,000.00).

3. Rule 114, Section 4 of the Rules of Court provides:

Sec. 4. Bail, a matter of right; exception. — All


persons in custody shall be admitted to bail as a
matter of right, with sufficient sureties, or released on
recognize as prescribed by law or this Rule (a) before
or after conviction by the Metropolitan Trial Court,
Municipal Trial Court, Municipal Trial Court in Cities,
or Municipal Circuit Trial Court, and (b) before
conviction by the Regional Trial Court of an offense not
punishable by death, reclusion perpetua, or life
imprisonment.

4. That the accused has been arrested on ________________


and is currently detained at Caloocan City Police Station,
____________.

PRAYER

WHEREFORE, it is respectfully prayed of this Honorable Court:

(1) that the accused ______________ be allowed to post bail for her
temporary liberty pending trial of the criminal charge against her.

Other just and equitable reliefs are likewise prayed for.

Respectfully submitted.
September 20, 2017, Caloocan City.

________________________
Accused

NOTICE OF HEARING

THE BRANCH CLERK OF COURT


Metropolitan Trial Court, Branch 00
Caloocan City

Office of the City Prosecutor


Caloocan City

Greetings!

Please take notice that the foregoing Motion for shall be


submitted for the immediate consideration and approval of the
Honorable Court.
_____________________

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 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 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