Republic of the PhilippinesREGIONAL TRIAL COURTNational Capital
Judicial RegionPasay City, Branch 98
THE PEOPLE OF THE PHILIPPINESComplainant,Criminal Case No. 38,
390-15 FOR: Violation of Section 10 (a), Article VI of Republic Act
No. 7610
-versus-
RONALD VERDUGOAccused.x--------------------------------x
PRE-TRIAL BRIEF
ACCUSED, through the undersigned counsel, before this Honorable
Court, most respectfully submit this Pre-Trial Brief.
A. ADMISSION AND STIPULATION OF FACTS
Other than those alleged in the Counter-Affidavit, none at the
moment.
B. EVIDENCE FOR MARKINGS
1. Counter Affidavit of Accused to prove the truthfulness of his
denials to the case as EXHIBIT A.2. Grades of Anna Cruz at her
former school as EXHIBIT B.3. Publicly displayed photos of Anna
Cruz with her friends drinking alcohol and smoking cigarettes,
public display of affection with a guy as EXHIBIT C.4. Photos of
the cigarettes and foils used for illegal drugs as EXHIBIT D.
C. ISSUES
1. Whether or not the Accused is committed the offense
charged;2. Whether or not the Accused was guilty thereof.
D. WITNESSES
1. Accused Ronald Trinidad to testify on the matters and
circumstances attending to the case.2. Anna Delo Santos and
Christian Del Flores to prove that the accused did not physically
and verbally abused the child.3. Natalie Estacia and Leidi Bayadun
to prove that the child has vices and stays outside until dawn.
E. TRIAL DATES
Specifically all Fridays of the month, with regular appearance
of the undersigned counsels before this Honorable Court.
RESPECTFULLY SUBMITTED.
City of Manila for Quezon City. 13 February 2015.
Assisted by counsel:
JASREEL DOMASING ROLL OF ATTORNEYS NO. 12345 IBP Lifetime No.
08888/Manila III PTR NO. 77777/Jan. 7, 2015/MLA MCLE Compliance:
IV-0002279/20 January 2012
Copy Furnished and Explanation
LEIDA MAE BUMANLAG#22 Maria Clara St., Zigzag RoadMapayapa,
Pasay City
The filing and/or service of the foregoing is/are via registered
mail or alternative courier due to absence of manpower to effect
personal filing and/or service and/or due to the distance involved
and time constraints. (Please disregard if the filling and/or
service was/were effected personally.)
JASREEL A. DOMASING
