REPUBLIC OF THE PHILIPPPINES

NATIONAL CAPITAL JUDICIAL REGION

Regional Trial Court
BRANCH 170, MALABON CITY

PEOPLE OF THE PHILIPPINES,

-versus- Crim. Case No. 16-0737 MN

FOR: VIOLATION OF RA 9516

JERICO MACATABAS y TINEBROSO,

Of No. 64 Bisig ng Nayon, Sangandaan,
Caloocan City
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PETITION FOR BAIL

COME NOW, accused JERICO MACATABAS y TINEBROSO,
assisted by the Public Attorneys Office, through the undersigned
counsel, and unto this Honorable Court, most respectfully avers that:

1. On 18th day of April 2016, accused was charged for the

crime of VIOLATION OF RA 9516. No bail was
allowed OR RECOMMENDED;

2. Section 13, Article III of the 1987 Philippine

Constitution states:

All persons, EXCEPT those charged with

offenses punishable by reclusion perpetua,
WHEN EVIDENCE OF GUILT IS STRONG, shall,
before conviction, be bailable by sufficient
sureties, or be released on recognizance as may
be provided by law. The right to bail shall not be
impaired even when the privilege of the writ of
habeas corpus is suspended. Excessive bail shall
not be required. emphasis ours

3. The same is enuncited in Section 7, Rule 114 of the

Revised Rules of Criminal Procedures provides:

Capital offense or an offense punishable

by reclusion perpetua or life imprisonment, not
bailable. No person charged with a capital
offense, or an offense punishable by reclusion
perpetua or life imprisonment, SHALL BE
ADMITTED TO BAIL WHEN EVIDENCE OF
GUILT IS STRONG, regardless of the stage of
criminal prosecution. emphasis ours

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 4. STATED DIFFERENTLY, WHEN THE EVIDENCE OF
GUILT OF THE ACCUSED IS NOT STRONG, HE MAY
BE ALLOWED TO POST BAIL AT THE DISCRETION
OF THE COURT UPON APPLICATION FOR
ADMISSION TO BAIL;

5. In the present case under consideration, it is our

humble submission that the evidence of guilt of the
herein accused is not strong.

PRAYER

WHEREFORE, in the interest of substantial justice and taking

into consideration the foregoing, it is most respectfully prayed of this
Honorable Court that the instant petition for bail BE GRANTED, and
consequently, the accused BE ALLOWED TO POST BAIL, AFTER
HEARING, in the amount to be determined by this Honorable Court.

Other relief and remedies, just and equitable under the

premises, are likewise prayed for.

Malabon City, 5 September 2017.

Assisted by:

PUBLIC ATTORNEYS OFFICE

MALABON CITY DISTRICT
Counsel for Accused
Khan Bldg., 160 Gov. W. Pascual Avenue
Tinajeros, Malabon City 1470

By:

Atty. MA. CHARISSE E. GAUD

Public Attorney I
MCLE Compliance V
Admitted to the Bar on June 2016
IBP No. 1069813
Roll of Attorney No. 66562

NOTICE

ATTY. JESUS HERNANDEZ

The Branch Clerk of Court
RTC-Branch 170
Malabon City

G r e e t i n g s!

Immediately upon receipt hereof, please submit the foregoing Petition

for Bail for the consideration and approval of the Honorable Court on
28 September 2017 or at any time most convenient to the Court.
.
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 Atty. MA. CHARISSE E. GAUD

Copy furnished (Personal Service):

ACP MARIANITO V. SAGSAGAT
Assistant City Prosecutor
Malabon City, Metro Manila