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COMES NOW Defendant _____________, by the undersigned counsel and unto this Honorable Court, most respectfully states: That the Defendant is in custody for the alleged commission of an offense punishable by (life imprisonment / reclusion perpetua); That no bail has been recommended for (his/her) temporary release, on the assumption that the evidence of guilt is strong; That the burden of showing that evidence of guilt is strong is on the prosecution, and unless this fact is satisfactorily shown, the defendant is entitled to bail as a matter of right. PRAYER 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. _____________, Philippines, __Date__.
(COUNSEL)
(NOTICE OF HEARING)