Republic of the Philippines

Republic of the PhilippinesNational Capital Judicial Region

Regional Trial Court

Branch ___

Pasay City

THE PEOPLE OF THE PHILIPPINES

Criminal Case No. 13-1992For: Violation of Art. 315. 2 (a) of the REVISED PENAL CODE OF THE PHILIPPINES..-versus-

VICTORIA RAYE ALBERTO y POBLETO

Accused,

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PRE-TRIAL BRIEF OF THE ACCUSED

ACCUSED, through the undersigned counsel, before the Honorable Court, respectfully submits this Pre-Trial Brief:

A. SUMMARY OF ADMITTED FACTS, AND PROPOSED

STIPULATION OF FACTS

The accused admits the following:

1. That the Honorable Court has jurisdiction over the case;

2. That the identity of the one charged in the information and that of the person arraigned is one and the same;

3. That I am the defendant in the case;

4. The identity of the offended party, Sheila Marie Alilio;

5. That complainant Alilio is an acquaintance of mine in Arellano University School of Law6. The fact that complainant Alilio was looking for employment opportunities abroad.

B. ISSUES TO BE TRIED

Whether or not accused is guilty of the crime charged.C. EVIDENCE FOR MARKINGS

1. Affidavit of accused, Victoria Raye P. Alberto Exhibit F a sworn written statement toprove that the acts of the accused did not constitute the crime of estafa in whatever form.

D. NAME OF WITNESS1. Accused Victoria Raye P. Alberto Accused will testify on her own

behalf to prove her innocence;

E. TRIAL DATES

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

RESPECTFULLY SUBMITTED. February 9, 2015, Pasay City, Philippines.

Atty. Christ Edgardo M. Aonuevo

Counsel for Defense

Roll No. 88761 / 05-30-08

IBP No. 823061 / 12-29-15

MCLE Compliance No. 772431/ 12-20-15

PTR No. 434629 / 01-05-16

Copy furnished:

PROS. DATU AMPATUAN

Assistant City Prosecutor

Pasay City Prosecution Office

Hall of Justice