REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

FOURTH JUDICIAL REGION
BRANCH 12
LIPA CITY, BATANGAS

THE PEOPLE
OF THE PHILIPPINES,
Plaintiff, CRIMINAL CASE NO.0582-98

- versus - for

MANOLITO GONZALES, MURDER

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

PETITION FOR BAIL

Accused MANOLITO GONZALES, by himself and unto this

Honorable Court, alleges:

1. That accused was charged with the offense of Murder which is a

non-bailable offense;

2. Under Section 7 of Rule 114 of the 1997 Rules of Court, it states

that:

“No person charged with a capital offense, or

an offense punishable by reclusion perpetua or life
imprisonment, shall be admitted to bail when
evidence of guilt is strong, regardless of the stage
of the criminal prosecution xxx”.

However, in the instant case the evidence against the

accused is not strong.

That prosecution witness Dante Ciruelas stated in his

sworn statement that accused Manolito Gonzales fired an
armalite to the victim, however, the said sworn statement
likewise indicates the fact that he did not witness the said
shooting incident as he was not able to know who shot the victim
Ernesto Valasquez after Glen Gonzales fired his pistol to the
victim. The pertinent portion of his sworn statement is hereunder
quoted, to wit:

" 09- T:Ilang beses binaril nitong si Glen Gonzales,

Arnaldo Boy Mendoza, Manoling Gonzales
at Ruperto de Villa itong si Ernesto
Velasquez?

S: Una po ang isang putok lamang si Glenn

Gonzales na pagkatapos ay nagsunod-
sunod na ang mga putok na hinde ko na
po malaman."
 WHEREFORE, it is respectfully prayed of this Honorable Court
that an order fixing the amount of bail for the provisional liberty of the
accused be issued, and that said accused be set at liberty upon the
filing of said bail.

Such other reliefs, just and equitable under the premises are
likewise prayed for.
Batangas City, March 10, 2008.

MANOLITO GONZALES
Accused

NOTICE OF HEARING

The City Prosecutor

Lipa City

The Branch Clerk of Court

Regional Trial Court
Branch 12, Lipa City

G R E E T I N G S:

Please take notice that this Petition for Bail will be

submitted for hearing on March ____, 2008 at 8:30 in the
morning.

MANOLITO
GONZALES

Copy furnished:

The City Prosecutor

Lipa City