REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

SEVENTH JUDICIAL REGION
BRANCH 88
MANDAUE CITY

PEOPLE OF THE PHILIPPINES

Plaintiff,

- versus - CRIM CASE NO. R-BHL-23-01-055-CR

For: ESTAFA

KIRK GUZMAN
Defendant,
x ----------------------------------------x

PETITION TO BAIL

Defendant in the above-entitled case, thru counsel, unto this

Honorable Court, respectfully states:

1. That the defendant is in custody for the alleged commission of

a capital offense;
2. That no bail has been recommended for his temporary release,
on the assumption that the evidence of guilt is strong;
3. That the burden of showing that evidence of guilt is strong is
on the prosecution, and unless this fact is satisfactorily shown,
the defendant may be bailed at the court’s discretion.
4. Attached in this petition is the medical certificate of a
competent medical doctor that may attest his condition that he
might not be suitable inside the jail.

WHEREFORE, upon prior notice and hearing, it is respectfully prayed

that the defendant be admitted to bail in such amount as this Honorable
Court may fix.

City of Tagbilaran, Philippines, March 01, 2023.

ATTY. ELMER B. NUEZ

Counsel of the Defendant