REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

JUDICIAL REGION
BRANCH

PEOPLE OF THE PHILIPPINES CRIM. CASE NO.: x

Plaintiff,

-versus- FOR: VIOLATION OF

SEC.5 OF RA 9165
x
Accused.
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PETITION FOR BAIL

ACCUSED, through the undersigned counsel, unto this

Honorable Court, most respectfully alleges, to wit:

1. That accused is currently detained at the xxx Jail for

Violation of Sec. 5 of RA 9165 (Comprehensive
Dangerous Drugs Act of 2002);

2. That no bail has been recommended for his

temporary liberty in the assumption that the
evidence of guilt is strong;

3. That the accused is entitled to post bail as a matter

of right;

4. Article 1, Section 13 of the Philippine Constitution

states:

Section 13. 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. xxx

The above section provides that the accused is

presumed innocent until proven guilty beyond
 reasonable doubt and 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, premises considered, it is most respectfully

prayed that a hearing for bail be set so that prosecution be given
an opportunity to prove that indeed its evidence against the
accused is strong.

Other just and equitable reliefs are likewise prayed for.

MOST RESPECTFULLY SUBMITTED.

Xxxx Philippines

Counsel for the Plaintiff