REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

SIXTH JUDICIAL REGION
BAGO CITY
Branch 62

PEOPLE OF THE PHILIPPINES,

Criminal Case Nos. 4313 to 4315

- versus - For: Sexual Abuse in relation to
R.A. 7610

EDDIE L. BAILON J.R.,

Accused.

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APPLICATION FOR PROBATION
Accused, Eddie Bailon, Jr., by counsel, respectfully states:

1. On May 23, 2021, this Honorable Court promulgated its

Decision finding the Accused guilty of the following crimes:

a. Acts of Lascviousness in Criminal Case No. 4313 with the

indeterminate penalty of imprisonment for a period of four (4)
months and one (1) day up to six (6) months as the minimum to
four (4) years, two (2) months and one (1) day to six (6) years
as the maximum.

b. Acts of Lascviousness in Criminal Case No. 4314 with the

indeterminate penalty of imprisonment for a period of four (4)
months and one (1) day up to six (6) months as the minimum to
four (4) years, two (2) months and one (1) day to six (6) years
as the maximum.

c. Acts of Lascviousness in Criminal Case No. 4315 with the

indeterminate penalty of imprisonment for a period of four (4)
months and one (1) day up to six (6) months as the minimum to
four (4) years, two (2) months and one (1) day to six (6) years
as the maximum.

2. In the same Decision, the Accused was further directed to pay

moral damages to the private complainants in the amount of Seventy-Five
Thousand Pesos (P75,000.00) each.

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 3.  In light of the foregoing, the Accused humbly manifests that he
will no longer appeal his conviction. Instead, he seeks to apply for the
suspension of the execution of his sentence by placing him on probation
under Presidential Decree No. 968 (otherwise known as the “Probation Law
of 1976,”) as amended by Republic Act 10707 for such period and upon
such terms and conditions that this Honorable Court may deem fit and
necessary.

4. The accused further manifests that he has all the qualifications

and none of the disqualifications to avail of the benefits of the Probation
Law under Section Nine (9) of the same decree (as amended by Section 2 of
R.A 10707) to wit:

i. He was not sentenced to serve a maximum prison term of

more than six (6) years;

ii. The crime for which he was convicted of was not an offense
against national security or public order;

iii. He has no previous conviction, by final judgment, of an

offense punished by imprisonment of more than six (6)
months and one (1) day and/or a fine of more than one
thousand pesos (P1,000.00); and

iv. He has not once availed of probation under the provisions

of Presidential Decree No. 968, otherwise known as the
Probation Law of 1976, as amended by Republic Act 10707.

RELIEF

         WHEREFORE, premises considered, it is most respectfully prayed of

this Honorable Court that the Application for Probation be referred to the
Parole and Probation Officer of Bago City for the requisite post-sentence
investigation, and, thereafter, the application for probation be approved;

Other equitable reliefs are likewise prayed for.

Bacolod City for Bago City, June 3, 2021.

CATACUTAN & SINCO

LAW OFFICES
Counsel for the Accused
Door No. 4, 2nd Floor,
Esteban – Magdalena Bldg.,

2
 Hernaez Street, Brgy 38, Bacolod City
Negros Occidental, 6100
Email Address: caslawoffices@gmail.com
Cell Phone No.: 0998-343-5104/0928-860-5361

By:

ACE JOSEPH B. CATACUTAN

PTR No. 7126822/01-04-18/Bacolod City
IBP No. LRN-028649/01-19-2018/
Negros Occidental Chapter
Attorney’s Roll No. 64091
MCLE Compliance No. V-0023218; 04-14-19

GABRIEL P. SINCO
PTR No. 7126821/ 01-04-18/Bacolod City
IBP No. LRN - 028650/ 01-19-2018/
Negros Occidental Chapter
Attorney’s Roll No. 67606
(Complied pending release of MCLE Comp. No.)

Copy furnished:

Atty. Ma. Christy E. Uriarte

The Honorable City Prosecutor
Hall of Justice, Bago City.