VERIFICATION AND CERTIFICATION OF NON-FORUM

SHOPPING
I, JUAN DELA CRUZ, of legal age, Filipino, married, after having
been duly sworn in accordance with law, depose and state that:
1. I am a plaintiff in the above-stated case;
2. I caused the preparation of the foregoing complaint;
3. I have read the contents thereof and the facts stated therein
are true and correct of my personal knowledge and/or on the
basis of copies of documents and records in my possession;
4. I have not commenced any other action or proceeding involving
the same issues in the Supreme Court, the Court of Appeals, or
any other tribunal or agency;
5. To the best of my knowledge and belief, no such action or
proceeding is pending in the Supreme Court, the Court of
Appeals, or any other tribunal or agency;
6. If I should thereafter learn that a similar action or proceeding
has been filed or is pending before the Supreme Court, the
Court of Appeals, or any other tribunal or agency, I undertake
to report that fact within five (5) days therefrom to this
Honorable Court.

JUAN DELA CRUZ

Affiant
SUBSCRIBED AND SWORN to before me this ___day of ________,
2016, in City of Manila, affiant exhibiting his Philippine Passport No. 12345
issued in Manila on 07 March 2011 valid until 07 March 2016.

NOTARY PUBLIC
Page No. ___;
Doc. No. ___;
Book No. ___;
Series of 2016.

Republic of the Philippines

National Capital Judicial Region

REGIONAL TRIAL COURT
Branch 1
Manila
PEOPLE OF THE PHILIPPINES,
Plaintiff,
Crim Case No. 12345
For: MURDER

- versus PEDRO DE MASUPIL,

Accused.
x - - - - - - - - - - - - - - - - - - - - -x

PETITION FOR BAIL

Accused, through the undersigned counsel, unto this Honorable
Court,most respectfully states:
1. That accused is currently detained at the Manila City Jail for the
charge of Murder;
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 based on the
sworn statement of Mando Duro who subsequently recanted his
testimonies and confessed, among others, that he was made to sign
the "affidavits of witnesses" against his will. Attached hereto is the
copy of the Affidavit of Recantation of Mando Duro as Annex A;
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 Pedro De Masupil 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.

16 March 2016 at Manila, Philippines.

JEFFREY L. SANTOS
Counsel for the Accused
PTR No. 54321, 03 January 2016
IBP No. 678910
Roll No. 12345:05/11/2014: Manila
Rm. 123 Westlake Building, Soler St.,
Binondo, Manila
NOTICE OF HEARING
THE BRANCH CLERK OF COURT
Regional Trial Court, Branch 1
Manila
Greetings!
Please submit the foregoing motion to the Honorable Court on 01
April 2016 at 2:00 oclock in the afternoon for its favorable consideration
and approval.

ATTY. JEFFREY L. SANTOS

Copy furnished:
Office of the City Prosecutor
Manila
ATTY. JOSE BAYOLA
Private Prosecutor
No. 69 Pilapil Street,
Sta. Ana, Manila