Republic of the Philippines

REGIONAL TRIAL COURT

11th JUDICIAL REGION
Branch 15
Davao City

PEOPLE OF THE PHILIPPINES,

Plaintiff,
Crim Case No. 12345
- versus - for : Frustrated Murder

LEO B. ESCALANTE Jr. ,

Accused.
x - - - - - - - - - - - - - - - - - - - - -x

PETITION FOR BAIL

Accused, through the undersigned counsel, unto this Honorable Court,

respectfully states:

1. That accused is currently detained at the Maa City Jail for the charge of
Frustrated Murder and has been behind bars since his arrest on February 12, 2020 ;

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 the
charges against him. The records will show that accused was malicious implicated
in the case through the sworn statements of Ron Chiu and Josef Reyes who
subsequently recanted their testimonies and confessed, among others, that they
were made to sign the "affidavits of witnesses" against their will. (copies of the
Affidavits of Recantation are hereto attached as Annexes "A" and "B")

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 LEO B. ESCALANTE Jr. be allowed to post bail for
his temporary liberty pending trial of the criminal charge against him.

Other just and equitable reliefs are likewise prayed for.

March 14, 2020, Davao City, Philippines

ATTY. ERICK JAY N. INOK

Counsel for the Accused
Notary Public / Roll of Attorneys No. 420696
Notarial Commission Serial No. 2019-420-2020
Commission Expires on December 31, 2020
IBP No. 030524; 01/10/2020; Davao City
PTR No. 1760152C; 01/04/2020; Davao City
MCLE Compliance No. VI–0012697 – 09/19/2019
Tel Nos. (082) 225-2066; (082) 241-2945
Email Address: ERICKSKIE23@yahoo.com
Legal Office, Commission on Audit R.O XI, Davao City

NOTICE OF HEARING

Atty. Salvador Pandesal

The Brach Clerk of Court
RTC Davao City, Branch 15

Please take notice that the undersigned counsel will submit the foregoing
Motion for the consideration and approval of the Court on March 25, 2020 at 8:30
AM, with or without appearance of counsel.
 Atty. Erick Jay N. Inok

Copy Furnished:
Copy furnished:
Atty. Izabel F. Serina Registry Receipt._____________________
Office of the City Prosecutor Date._______________________________

EXPLANATION
(please disregard if served by personal service)

Due to lack of available office/messengerial personnel, and time constraints,

service by registered mail of this motion on the other parties aforementioned were
resorted to.

Atty. Erick Jay N. Inok