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Pretrial Brief For The Prosecution

The document summarizes a pre-trial brief for the criminal case of People of the Philippines vs. Erick John Paul P. Saysay for rape under Article 266(b) of the Revised Penal Code. The brief lists admitted facts of the case including the identities of those involved, details of the crime, and authenticity of evidence. It also outlines proposed evidence, issues to consider, witnesses, and scheduled trial dates.

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Khay Gonzales
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489 views3 pages

Pretrial Brief For The Prosecution

The document summarizes a pre-trial brief for the criminal case of People of the Philippines vs. Erick John Paul P. Saysay for rape under Article 266(b) of the Revised Penal Code. The brief lists admitted facts of the case including the identities of those involved, details of the crime, and authenticity of evidence. It also outlines proposed evidence, issues to consider, witnesses, and scheduled trial dates.

Uploaded by

Khay Gonzales
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

National Capital Judicial Region


REGIONAL TRIAL COURT
Branch 1
Pasay City

PEOPLE OF THE PHILIPPINES, CRIMINAL CASE NO. 5678


(NPS XV-13 INV-18-A-00001)
Plaintiff, FOR: RAPE UNDER Art. 266 (b) of
the Revised Penal Code, as
amended.
- versus -

ERICK JOHN PAUL P. SAYSAY,

Accused.
x-----------------------------------------------x

PRE-TRIAL BRIEF OF THE PROSECUTION

THE PEOPLE OF THE PHILIPPINES, through the undersigned City


Prosecutor, before this Honorable Court, most respectfully submit this Pre-Trial
Brief:
SUMMARY OF ADMITTED FACTS
AND PROPOSED STIPULATION OF FACTS

The following are the admitted facts:

1. The identities of those charged in the information and that of the


persons arraigned are one and the same being Erick John Paul Pili
Saysay;
2. The identity of MA. CONSORCIA A. GOLEA, the victim;
3. The commission of rape against the person of the victim;
4. The age of the victim being 11 years old;
5. The date and places of the commission of the crime being January 19,
2019, at No. 100, Shell Residences, Pacific Drive, Sunset Avenue,
Pasay City;
6. The authenticity of CCTV Footage.
EVIDENCE FOR MARKINGS

1. Affidavit of Jiehan A. Diagao


Purpose: to corroborate with the sworn statement and testimonies of the
victim;
2. Affidavit of the victim, Ma. Consorcia A. Golea Bea Robles
Purpose: to prove that the accused had carnal knowledge of the person of
the victim;
3. Crime Report prepared by Police Officer Joice G. Geluz
Purpose: to corroborate with the sworn statement and testimonies of the
victim;
4. Affidavit of the medico-legal expert, NADINE XYRA C. ESPIRITU
Purpose: to corroborate with the sworn statement and testimonies of the
victim and to prove that the accused obtained carnal knowledge on the
person of the victim by use of force, and to authenticate the medico-legal
examination, specifically Genital Examination, conducted upon the person
of the victim;
5. Memorandum of request for Genital Examination prepared by
the Chief of Pasay City Police Station
Purpose: to corroborate with the authenticity of the medico-legal
examination conducted upon the person of the victim;
6. Birth Certificate of the victim, Ma. Consorcia A. Golea
Purpose: To prove the age of the victim when the commission of the
crime transpired;
7. CCTV Footage taken inside Shell Residences
Purpose: To prove the presence of the accused inside the premises of the
place where he committed the crime against the victim;
8. Affidavit of the Head of Security Office of Shell Residences,
Dana Mae Clemencia
Purpose: To prove the authenticity of the CCTV Footage taken inside the
place of the commission of the crime.

ISSUES
1. Whether or not the crime charged has been committed;
2. Whether or not the accused is guilty thereof.
WITNESSES

1. Ma. Consorcia A. Golea, to testify as the victim;


2. Jiehan A. Diagao, to testify on the personal circumstances of the
victim;
3. Police Officer Joice G. Geluz, to testify on the crime reported by the
victim and the consequential arrest of the accused;
4. Nadine Xyra C. Espiritu, to testify on the authenticity of the medico-
legal examination;
5. Dana Mae Clemencia, to testify on the authenticity of the CCTV
Footage.
TRIAL DATES

Specifically all Fridays of the month, with the regular appearance of the
undersigned city prosecutors before this Honorable Court.

RESPECTFULLY SUBMITTED.

Pasay City, Metro Manila, Philippines, February 8, 2019.

OFFICE OF THE CITY PROSECUTOR OF


PASAY CITY
G/F, Hall of Justice, F.B. Harrison St., Pasay City

By:

KEVIN G. PEREZ
Assistant City Prosecutor
Roll of Attorney’s No 123456
MCLE Compliance No. V-0101010
IBP No. 123456

DANNA CLEMENCIA
Chief City Prosecutor

Copy furnished:

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