Republic of the Philippines

Department of Justice
National Prosecution Service
OFFICE OF THE CITY PROSECUTOR
Makati City
AFFIDAVIT OF DESISTANCE
WE, FERDINAND M. CASTRO and ROWENA A. CASTRO, Filipinos,
of legal ages, husband and wife, respectively, and residents of 106
Sisa Street, Sampaloc, Manila after having been duly sworn to in
accordance
with
law,
depose
and
state:
1. We are the private complainant in a criminal case for Reckless
Imprudence Resulting to Damage to Property against Joel O. Castillo
docketed as IS No. XV-05-INV-10G-01000 before the Office of the City
Prosecutor, Makati City
2.

In this regard, the accused has already paid the damage to our
vehicle;

3. In view of the payment by the accused and considering that Rowena A.

Castro was not injured, we would like to manifest that we now
completely and absolutely exonerate the accused from any liability in
connection with the above-mentioned criminal case and that we are no
longer interested, and we hereby desist, in prosecuting the said
criminal case;
4. As such, we respectfully pray that the aforementioned case against
Joel O. Castillo be withdrawn and/or dismissed.
IN WITNESS WHEREOF, we have hereunto set our hands
this ___________________ in _______________, Philippines.

FERDINAND M. CASTRO

ROWENA A. CASTRO

Affiant

Affiant

Philippine
Passport
No.
_____ Philippine
Passport
No.
___
Issued
at:
________________ Issued
at:
______________
Issued on: ________________
Issued on: _______________

SUBCRIBED
AND
SWORN
TO before
me
this ___________________ in
_________________, Philippines,
affiants exhibiting to me their valid proofs of identification.
Doc. No. _____;
Page No. _____;
Book No. _____;
Series of 2013.

Republic of the Philippines

National Capital Judicial Region
REGIONAL TRIAL COURT
Branch 147
Makati City
PEOPLE

OF

THE

PHILIPPINES,

Plaintiff,
Crim
Case
- versus for

No. 12345
Frustrated Murder

AKU SADO,
Accused.
x - - - - - - - - - - - - - - - - - - - - -x

PETITION FOR BAIL

Accused, through the undersigned counsel, unto this Honorable
Court, respectfully
states:
1. That accused is currently detained at the Makati City Jail for the charge
of Frustrated Murder and has been behind bars since his arrest on
August 1, 2013;
2. That no bail has been recommended for his temporary release on the
assumption that the evidence of guilt is strong;
3. That the prosecution's evidence of guilt against accused, however, is
weak as there is no direct evidence that will point to the accused to
have committed the the charges against him. The records will show
that accused was malicious implicated in the case through the sworn
statements of SINU NGALING and BULA AN who subsequently
recanted their testimonies and confessed, among others, that they
were made to sign the "affidavits of witnesses" against their will.

(copies of the Affidavits of Recantation are hereto attached as Annexes

"A" and "B")
4. That there is no other physical or documentary evidence to show that
accused is guilty of the crime charged;.
5. That the burden of showing that evidence of guilt is strong is on the
prosecution, and since this fact is not satisfactorily shown, accused is
entitled to bail as a matter of right during the pendency of the criminal
case.
WHEREFORE, upon prior notice and hearing, it is respectfully
prayed of this Honorable Court that accused AKU SADO 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.
15 August 2013
City of Makati.
ATTY. VX YZ
Counsel for the Accused
NOTICE OF HEARING
THE BRANCH CLERK OF COURT
Regional Trial Court, Branch 147
Makati City
Greetings!
Please submit the foregoing motion to the Honorable Court on
August 27, 2013 at 8:30 in the morning for its favorable consideration
and approval.

VX YZ
Copy

furnished

by

PROSECUTOR WX
Office of the City Prosecutor, Makati City
ATTY. AB CD
Private Prosecutor
2233 Zamora Street, Pasay City

personal

service:
YZ