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Pre Trial

This document is a pre-trial brief submitted by the defense counsel for Christopher R. Cabacungan, who has been charged with rape. The brief outlines several key points: (1) the accused is willing to enter an amicable settlement or alternative dispute resolution; (2) the accused admits his identity but denies guilt; (3) proposed witnesses include the alleged victim and two others; (4) proposed documentary exhibits include sworn statements from witnesses; (5) the defense will not avail of discovery procedures or referrals to commissioners. The brief reserves the right to present additional witnesses and exhibits during trial if necessary.

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TJ Julian Baltazar
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231 views

Pre Trial

This document is a pre-trial brief submitted by the defense counsel for Christopher R. Cabacungan, who has been charged with rape. The brief outlines several key points: (1) the accused is willing to enter an amicable settlement or alternative dispute resolution; (2) the accused admits his identity but denies guilt; (3) proposed witnesses include the alleged victim and two others; (4) proposed documentary exhibits include sworn statements from witnesses; (5) the defense will not avail of discovery procedures or referrals to commissioners. The brief reserves the right to present additional witnesses and exhibits during trial if necessary.

Uploaded by

TJ Julian Baltazar
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

REGIONAL TRIAL COURT


Second Judicial Region
Branch 21
Santiago City

PEOPLE OF THE PHILIPPINES,


Plaintiff,

-versus- CRIM.CASE NO. 12443


For: Rape

CHRISTOPHER R. CABACUNGAN,
Accused.
x--------------------------------------------x

PRE-TRIAL BRIEF

Accused duly assisted by the undersigned counsel unto this


Honorable Court, most respectfully submits the foregoing Pre-Trial Brief
and avers:

I. Amicable Settlement or Alternative Dispute Resolution;

Accused is willing to enter into an amicable settlement under such


terms and conditions that are just and reasonable under the
circumstances. He is likewise open to any alternative mode of dispute
resolution.

II. A. Admitted fact/s;

1. The identity of the accused is admitted.


III. Proposals for Admission:

1. The accused is a Tricycle driver in whom the private


complainant asked for a favor to pick up and fetch the latter
before and after school; and

2. The accused and the private complainant were sweethearts.

IV. ISSUES:

(A) WHETHER OR NOT THE ACCUSED IS GUILTY OF


THE CRIME CHARGED?

IV. WITNESSES;

1. Novilyn L. Domingo;
2. Lolita M. Bergonia;
3. Lea V. Dangngay.

The accused is reserving his right to present additional witnesses


during trial if necessary and upon good cause shown;

V. DOCUMENTARY EXHIBITS;

EXHIBIT PARTICULARS

“A” - Sinumpaang Salaysay of Novilyn


L. Domingo
“B” - Pinagsamang Sinumpaang
Salaysay of Lolita M.
Bergonia and Lea V. Dangngay

The Defense is reserving the presentation and marking of additional


documentary exhibits during trial if necessary and upon good cause
shown;

VI. Discovery procedures; Referral to commissioners:

a. Accused will not avail of discovery procedures/referral to


commissioners;

VII. Applicable laws;

(a) Rules of Court;

(b) Revised Penal Code;

VIII. Trial Dates;

a) The defense shall defer to the availability of the courts


calendar;
RESPECTFULLY SUBMITTED

Santiago City for Maddela, Quirino, 11 September 2018.

THE LAW OFFICES OF DAMASEN & SUBIA


Unit 5, Mango Suites, Calao East, Santiago City
E-mail: [email protected]
Mobile No.: 09178730405
Tel. No.: (078) 305-2392

By:

ATTY. LUCKY M. DAMASEN


Private Prosecutor
MCLE Compliance No. V-008089/06-04-15

PTR No. 2398537/Santiago City/01-03-2018

IBP No. 021276/IBP National Office, Pasig City/05-03-2018

Roll No.37959/07-24-92

WITH MY CONFORMITY:
___________________________

Prosecutor

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