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Urgent Bail Petition for Detained Diabetic

The petitioner is currently detained at the CIDG Cebu City Field Unit 7 on charges of violating PD 1865. No criminal complaint has been filed with the city prosecutor and no inquest proceedings have been conducted. The petitioner is requesting bail pending the inquest proceedings and filing of formal charges, as allowed under the Rules on Criminal Procedure. The petitioner is also diabetic and at high risk for COVID-19 complications, and strict health protocols are not being followed at the detention center. The petitioner pledges to submit to the proper authorities. Bail is being requested for humanitarian reasons and not to delay proceedings. The petitioner requests that the court set a bail amount and order their immediate release upon posting of bail

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129 views3 pages

Urgent Bail Petition for Detained Diabetic

The petitioner is currently detained at the CIDG Cebu City Field Unit 7 on charges of violating PD 1865. No criminal complaint has been filed with the city prosecutor and no inquest proceedings have been conducted. The petitioner is requesting bail pending the inquest proceedings and filing of formal charges, as allowed under the Rules on Criminal Procedure. The petitioner is also diabetic and at high risk for COVID-19 complications, and strict health protocols are not being followed at the detention center. The petitioner pledges to submit to the proper authorities. Bail is being requested for humanitarian reasons and not to delay proceedings. The petitioner requests that the court set a bail amount and order their immediate release upon posting of bail

Uploaded by

Rave Master
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd

Republic of the Philippines

____________ Judicial Region


MUNICIPAL TRIAL COURT
Branch _____

Spec Proc No. ______

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

URGENT PETITION FOR BAIL

Petitioner, through the undersigned counsel, unto this Honorable Court,


respectfully states that:

1. The petitioner is currently detained at


the ______________________________________________ for the
charge of Violation of
_____________________________________________________ and
has been detained since his arrest
on ____________________________________, which is a Friday. A
copy of the Certificate of Detention is hereby attached and made an
integral part hereof as Annex “A”.
2. As of the moment, no criminal complaint for alleged violation of PD
1865 was filed before the Office of the City Prosecutor neither an
Inquest Proceedings was ever conducted. In short, there is no case
that is filed yet before the Office of the City Prosecutor and or the
proper court in connection with the case;
3. The Petitioner are pleading the indulgence of this Honorable Court
for the allowance of BAIL pending the inquest proceedings and filing
of the proper information against the Petitioners in court by the
Mandaue City Prosecutor’s Office pursuant to Paragraph (c), Section
17 of the Revised Rules on Criminal Procedure which provides:

“(c) Any person in custody who is not yet charged in court may
apply for bail with any court in the province, city or
municipality where he is held”

4. The Petitioner is diabetic which is considered as high-risk in


contracting severe complications when infected by COVID-19. Other
than the petitioner, there were many other detainees at the CIDG
Cebu City Field Unit 7 and some did not even wear face masks.

1
Considering that strict protocols are not followed at the CIDG Cebu
City Field Unit 7 then the longer petitioner is detained there the
more at risk he is in contracting COVID-19.
5. That Petitioners faithfully undertake to submit themselves to the
court or any government authorities whenever their presence is
required or necessary in connection with the instant case;
6. That the instant case is “BAILABLE” in nature thus Petitioners are
qualified to apply for bail considering that the main purpose for bail
is to guarantee the appearance of the accused at the trial, or
whenever so required by the court;
7. That considering that no information was yet filed by the Mandaue
City Prosecutor’s Office, there is a need for the Honorable Court to fix
the amount of bail bond for each of the Petitioner on account of the
crime by which they were apprehended;
8. That this instant Petition is not intended to delay proceedings of this
case but for reasons above stated particularly for humanitarian
reasons;

PRAYER

WHEREFORE, PREMISES CONSIDERED, it is most respectfully prayed


the following:

1. That the instant Petition be GRANTED and an Order be issued


fixing the bail of the herein Petitioners in accordance with the bail
bond guide pending the filing of the proper Information in Court;

2. Issue an Order directing the Station Commander of Criminal


Investigation and Detection Group (CIDG) Cebu City Field Unit 7,
Camp Sotero Cabahug, Gorordo Avenue, Cebu City and/or any
authorities concerned, who are in ACTUAL CUSTODY of the
Petitioners to IMMEDIATELY RELEASE them upon posting of the
bond fixed by this Honorable Court, unless they are detained for
some other legal charge or charges.

Other relief and remedies that are just and proper under the
circumstances are likewise prayed for.

Respectfully Submitted.
Cebu City, Philippines, March 22, 2021.

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By:

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