Republic of the Philippines

REGIONAL TRIAL COURT

9th Judicial Region
Branch 18
Pagadian City
-o0o-

PEOPLE OF THE PHILIPPINES. CRIM. CASE NO. 13206-2K16

Plaintiff,

-versus- -for-

AHBAB SALILAMA ABBAS VIOLATION OF

a.k.a “BAB” , SECTION 5 IN
BADRODEN ABO y TUMOG RELATION TO SEC. 26
a.k.a “BADZ”, ARTICLE II OF R.A.
SADDAM DOLONAN AMPATU 9165
a.k.a “DAM”,
Accused.
x-------------------------------------------x

MOTION TO ADMIT BAIL

COMES NOW, Accused AHBAB SALILAMA ABBAS, through

undersigned counsel, unto the Honorable Court, most respectfully states
and avers: THAT-

1. Accused is presently detained at the Pagadian City Jail of the Bureau

of Jail and Penology Management, Barangay Lenienza, Pagadian
City and is under detention since his arrest;

2. There is no bail recommended for the temporary liberty of the

accused on the assumption that the evidence of guilt against the
Accused is strong;

3. That the burden of showing that evidence of guilt is strong is on the

prosecution, and unless this fact is satisfactorily shown, the Accused
is entitled to bail as a matter of right.

PRAYER

WHEREFORE, upon prior notice and hearing, it is respectfully

prayed that the Defendant _____________ be admitted to bail in such
amount as this Honorable Court may fix.

_____________, Philippines, __Date__.

 SHINE NOVEL L. SAIPUDIN
Counsel for Accused AHBAB SALILAMA ABBAS
Roll of Attorney No. 66798
PTR No. 2910296 - 5/31/2017- Pagadian City
IBP O.R. No. 006004 – 5/19/2017- Zamboanga del Sur
MCLE Compliance No. (Admitted to the BAR on 23 May 2017)
0451 Purok Ferdinand, Sto. Niño District Pagadian City

NOTIFICATIONS

BRANCH CLERK OF COURT

Branch 18
Regional Trial Court
Pagadian City

Greetings! Please submit the foregoing motion, to the

Honorable Court, for hearing on _______________ at
_________________, for the kind consideration and approval of the
Honorable Court.

ATTY. SHINE NOVEL L. SAIPUDIN

CITY PROSECUTION OFFICE

City of Pagadian

Greetings! Please be informed that the undersigned counsel will

submit the foregoing motion to the Honorable Court, for hearing, on
__________________ at __________________ for its kind
consideration and approval.

ATTY. SHINE NOVEL L. SAIPUDIN

Copy Furnished:
City Prosecution Office _____________________
Pagadian City