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Pre Trial Brief Accused Docx 1

This document is a pre-trial brief submitted by the defense counsel for Mr. Juan, who is accused of violating RA 9262 (Violence Against Women and Children Act). The brief summarizes the admitted facts, including that Mr. Juan has two children with another woman and is married to Juana. It also lists the issues to be tried, evidence to be presented, witnesses, and the possibility of an amicable settlement. The defense counsel is available for trial on January 3, 18, or 30, 2018.

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758 views4 pages

Pre Trial Brief Accused Docx 1

This document is a pre-trial brief submitted by the defense counsel for Mr. Juan, who is accused of violating RA 9262 (Violence Against Women and Children Act). The brief summarizes the admitted facts, including that Mr. Juan has two children with another woman and is married to Juana. It also lists the issues to be tried, evidence to be presented, witnesses, and the possibility of an amicable settlement. The defense counsel is available for trial on January 3, 18, or 30, 2018.

Uploaded by

kaizen shinichi
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
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Republic of the Philippines

MUNICIPAL TRIAL COURT


Lingayen, Pangasinan

MRS. Juana , CRIMINAL CASE NO.


Plaintiff,
FOR: Violation of RA 9262
-versus- Violation against women and
children
MR. Juan
Accused.
x-----------------------x

PRE-TRIAL BRIEF FOR ACCUSED

THE ACCUSED, through the undersigned Counsel, before this Honorable


Court, most respectfully submits this Pre-Trial Brief:

SUMMARY OF ADMITTED FACTS AND PROPOSED STIPULATION


OF FACTS

The following are the proposed stipulation of facts:


1. The accused has two children with MILAGROS D. BALICAN-
MACATOL namely Julie Anne and Joana May.
2. The accused and JUANA were lawfully married at the Immaculate
Concepcion Parish.
3. That MAGDALENA PINILI is a homosexual, namely a lesbian who
has a romantic relationship with one AYRA BATACAN.
4. That MAGDALENA PINILI is the childhood friend and household
helper of the accused receiving a fixed monthly salary from him.
ISSUE TO BE TRIED
Whether or not the accused is guilty of the crime charged.

EVIDENCE FOR MARKING

1. Affidavit of the accused marked as “Exhibit 1”


Purpose: To prove that the accused did not lay hands to JUANA.
To prove that the accused supports his wife and his
children.

WITNESSESS
1. Accused JUAN to testify that he never battered the plaintiff
2. Magdalena Pinili to testify that she is a homosexual lesbian since
childhood and has interests only on people of the same gender as
hers.
3. Ayra Batacan to corroborate the testimony of Magdalena Pinili that
she is a lesbian and to prove that the latter has a romantic
relationship with the affiant.

POSSIBILITY OF AMICABLE SETTLEMENT


That the accused is open and willing to submit this case to any alternative
mode of dispute settlement and likewise they are willing to settle this case
amicably provided that the terms and conditions thereof are fair and
reasonable.

AVAILABLE TRIAL DATES


The undersigned counsel is available for trial on any of the dates of January
3, 18, and 30, 2018. The undersigned counsel also respects the calendar of
this Honorable Court and agrees to other dates that may be set during the
pre-trial as may be convenient to the counsel for the plaintiff and the
Honorable Court.

RESPECTFULLY SUBMITTED
Respectfully submitted this 06 January 2018 at Baganga, Philippines.

Alpas, Lomondot & Jardinel Law Firm


Room D-100, Dotterweich Building
E. Jacinto Street, Davao City
By:

Atty. ALPAS, FRANCIS ANTHONY CRIS


C.
Counsel for the Defense
Roll No. 33333 / 03-03-2018
IBP No. 181818 / 03-03-2019
MCLE Compliance No. 181833 / 03-2018
PTR No. 1818333/ 3-18-2018

and

Atty. LOMONDOT, SARAH JANE


Counsel for the Defense
Roll No. 128374 / 09-01-2018
IBP No. 283984 / 10-20-2019
MCLE Compliance No. 287364 / 3-2-2018
PTR No. 273837/ 12-29-2019

Copy furnished by personal service:


ATTY. MEL CATHERINE MIRANDA
Prosecutor III
Davao City Prosecution Office

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