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2. That the latter motion was anchored from the perusal of the exhibits
offered by the prosecution as well as the oral testimonies of
witnesses presented in court, which made it clear that the same will
never link to any evidence that it was the accused Taytayan who shot
the victim, in fact no eyewitness was presented to establish the
Prosecution’s theory, thus failing to establish the guilt of the accused
nor establish the elements of murder making the accused entitled to
post bail;
4. That to relieve the accused from the rigors of imprisonment until his
conviction and yet secure his appearance at trial, the expedient
resolution of the Motion to Grant Bail is glaringly exigent;
5. That this motion is intended solely for the purpose alluded thereto;
PRAYER
NATHANIEL N. CLARUS
Counsel for the Accused
Room 508 SUGBUTEL BLDG.,
NORTH RECLAMATION AREA, CEBU CITY
Contact Nos.: 233-6329; 512-3085
IBP LIFETIME NO. 1058951/1-3-17
CEBU CITY
PTR NO. O.R. CEB- 177914
Issued on 1/4/19
ROLL NO. 38708
MCLE COMPLIANCE NO. 0015044
Issued on April 16, 2016
GREETING:
Please submit the foregoing to the Honorable Court for its
consideration and resolution immediately upon receipt hereof.
NATHANIEL N. CLARUS
HON. WILFREDO PANGANDOYON
Assistant City Prosecutor
City Prosecution Office
Mandaue City
Please take notice that counsel has requested for the approval of
this motion immediately upon receipt.
NATHANIEL N. CLARUS
COPY FURNISHED: