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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT


10th Judicial Region
BRANCH 10
Malaybalay City

PEOPLE OF THE PHILIPPINES CRIM. CASE NO. 27234-15


Plaintiff,
For: ILLEGAL SALE OF
-versus- DANGEROUS DRUGS

ALLAN BACHOCO y JAMEN


Accused

x------------------------------------------x

MOTION TO POST BAIL

Accused, through the undersigned counsel, unto this Honorable


Court, respectfullystates:

1. That accused is currently detained at the Malaybalay City


Jail for the charge of Illegal Sale of Dangerous Drugs and has
been behind bars since his arrest on September 5, 2015;

2. That no bail has been recommended for his temporary


release on the ground that the offense charged is non-
bailable as provided for by law;

3. That as gleaned by the record of the case, the prosecution's


evidence of guilt against the accused is not strong; thust the
accused may be allowed by the Honorable Court as a matter
of right to post bail consistent to Section 13, Article III of the
Constitution which provides that "All persons, except those
charged with offenses punishable by reclusionperpetua when
evidence of guilt is strong, shall, before conviction, be
bailable by sufficient sureties, or be released on recognizance
as may be provided by law.

4. That the burden of showing that evidence of guilt is strong


is on the prosecution, and until this fact is satisfactorily

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shown, the accused is entitled to bail as a matter of right
during the pendency of the instant case.

WHEREFORE, upon prior notice and hearing, it is


respectfully prayed of this Honorable Court that accused ALLAN
BACHOCO y JAMEN, 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.

Respectfully submitted. 30 October 2017.

Don Carlos for Malayalay City, Bukidnon

ATTY. FLORENTINE T. GARAY


Counsel for the Accused
Roll No. 65136; IBP Lifetime No. 015158
PTR No. 5690403, 01-04-2017; TIN-199-588-890
MCLE Compliance No. VI - 0001711

F. T. Garay Law Office


Door 2, FS Garay Bldg., Sayre Highway,
Don Carlos, Bukidnon 8712
Mobile No. 09177192662
Email address: ftgaray@gmail.com

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NOTICE OF HEARING

MERCED A. OMAMALIN
OIC Branch Clerk of Court
Regional Trial Court, Branch 10
Malaybalay City

Greetings!

Please submit the foregoing motion to the Honorable Court on


November 6, 2017 at 9:00 in the morning or soon thereafter as
counsels may be heard for its favorable consideration and approval.

30 October 2017 in Don Carlos for Malaybalay City, Bukidnon.

ATTY. FLORENTINE T. GARAY


Counsel for the Accused

Copy furnished by personal service to:

OFFICE OF THE CITY PROSECUTOR


Hall of Justice, Capitol Grounds
Malaybalay City, Bukidnon

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