First Judicial Region Branch 59 La Trinidad, Benguet
PEOPLE OF THE PHILIPPINES,
Plaintiff, Criminal Case No. 2015-0085 -versus- For:
AUGUSTUS CAESAR, Reckless
Imprudence Accused. Resulting to Homicide
PETITION FOR BAIL
Accused, through the undersigned counsel, unto this Honorable Court, respectfully states: 1. That accused is currently detained at the La Trinidad Police Station for the charge of Reckless Imprudence Resulting to Homicide and has been behind bars since his arrest on April 20, 2015; 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 the accused, however, is weak because the records will show that accused was maliciously implicated in the case through the sworn statements of May and July who subsequently recanted their testimonies and confessed, among others, that they were made to sign the "affidavits of witnesses" prepared by the police officers of La Trinidad, Police Station. Thus, being in a state of intoxication they signed the said affidavits without their free will. (Copies of the Affidavits of Recantation are hereto attached as Annexes "A" and "B") 4. 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 that accused AUGUSTUS CAESAR be allowed to post bail for his temporary liberty pending trial of the criminal charge against him in such amount as this Honorable Court may fix. Other just and equitable reliefs are likewise prayed for. La Trinidad, Benguet, Philippines, this 21st day of May, 2015. Dakila Del Campo-Domondon Counsel for the Defendant No. 17 Karunungan Bldg. Legarda Rd., Baguio City Tel. No. 442-2132 Roll of Attorneys No. 37217, 05-21-08 PTR No. 12343/ 01-31-15/Baguio City IBP Lifetime Membership No. 910/04-23-08/Baguio City IBP Baguio-Benguet Chapter MCLE Compliance No. 9876/05-20-2013 Serial No. Of Commission 322-662-01
NOTICE OF HEARING
THE BRANCH CLERK OF COURT
Regional Trial Court La Trinidad, Benguet, Branch 59
Please submit the foregoing Motion to the Court for its
consideration and approval immediately upon receipt hereof.
Please take notice that counsel has requested to be
heard on Monday, 25 April 2015 at 8:30 in the morning.
Dakila Del Campo-Domondon
Counsel for the Accused
Proof of Personal Service
Copy furnished through personal service:
Prosecutor William T. Bacoling
Provincial Prosecutors Office, Benguet
Atty. James Fernandez
Chan-Fernandez-Tangkia Law Office Rm. 3, UOB Bldg., Gen. Luna Rd., Baguio City