Republic of the Philippines

Eight (8th) Judicial Region

REGIONAL TRIAL COURT
Branch 129
Catbalogan City

PEOPLE OF THE PHILIPPINES,

Plaintiff,

- versus - CRIM CASE NO. M-

MNL-18-01417
FOR:
ESTAFA Art.315, Par.2 (a)
RPC

SHELLA S. BUCATCAT,
Accused.
x-------------------------------x

PETITION FOR BAIL

ACCUSED, through the undersigned counsel, unto this

Honorable Court, respectfully states:
 1. That accused is currently at large from the time
of issuance of Warrant of Arrest on February 28, 2018
issued by the National Capital Judicial Region Municipal
Trial Court up to present;

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.

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
SHELLA S. BUCATCAT be allowed to post bail for his temporary
liberty pending trial of the criminal charges against her.

Other just and equitable reliefs are likewise prayed for.

 Respectfully submitted.

05 July 2018
City of Catbalogan.

ACUBA AND ACUBA LAW OFFICES

Counsel for the Petitioner
196 G/F Laohoo Bldg., San
Bartolome St.
Brgy. 3, 6700
Catbalogan City

By:
DEMETRIO MEDINO J. ACUBA
PTR No. 56940436.19.18Catbalogan City
Roll of Attorneys No. 71321
IBP O.R. No. 039892 08 May 2018
MCLE Exempt

NOTICE OF HEARING