REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

Branch 43
MANILA

PEOPLE OF THE PHILIPPINES,

Complainant,
Criminal Case No. 7655
-versus-
For: Theft
Benito Cruz,
Accused.
x-------------------------------------------x

PETITION FOR BAIL

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

respectfully state:

1. That accused is currently detained at the Manila City Jail for the
charge of theft and has been behind bars since his arrest on June
14, 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 pin the accused to
the charge made against him.

4. That there are evidence showing that the CCTV footage assigned
as Annex “C”, which was used to put the accused on the place
where the crime was allegedly committed, was doctored according
to our expert witness.

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 BENITO CRUZ 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.

1
 Respectfully submitted.

City of Manila, 18 December 2020.

ATTY. DIONISIO C. BELGA

Counsel for Accused
PTR No. 93892; SFC 2/20/2020
IBP O.R. No. 458214; 5/12/2020
Attorney’s Roll No. 54214

Copy Furnished

ATTY. ANALIZ VALENZUELA

Solicitor General
454 Sixto Street, St. Charbel,
Mindanao Ave., Quezon City.

NOTICE OF HEARING

THE BRANCH CLERK OF COURT

Regional Trial Court, Branch 43
Manila City

Greetings!

Please submit the foregoing motion to the Honorable Court on

January 4, 2020 at 10:30 in the morning for its favorable consideration and
approval.

ATTY. DIONISIO C. BELGA