sample of pretrial brief for the defense | Brief (Law) | Witness

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Blotter Report of Molo Police Station (ICP-PP4) CRIMINAL CASE NO.______ FOR: MURDER. Purpose: to prove that the accused ...

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Republic of the Philippines Sixth Judicial Region REGIONAL TRIAL COURT

Branch___ Iloilo City

PEOPLE OF THE PHILIPPINES,

Plaintiff,

CRIMINAL CASE NO._______ FOR: MURDER

- versus GABRIEL SALAS, ALFREDO GOLEZ, AND GREG FAJARDO,

Accused. x-----------------------------------------------x PRE-TRIAL BRIEF OF THE ACCUSED

ACCUSED, through the undersigned counsel, before this Honorable Court,

most respectfully submit this Pre-Trial Pre-Trial Brief:

SUMMARY OF ADMITTED FACTS   AND PROPOSED STIPULATION OF FACTS 

The accused admit the following: 1. the the iden identi titie ties s of thos those e charg charged ed in the the infor informa mati tion on and and that that of the the persons arraigned are one and the same; 2. the identity of Sulpicio Treyes, the victim; 3. the killing of the victim; 4. the date, place and time of the killing, which was May 5, 2008 at about 1:30 in the morning and at Corner Valeria-De Leon Sts., Iloilo City. City.

EVIDENCE FOR MARKINGS 

1. Affidavit of accused, Gabriel Salas Purpose: to prove that he admits the killing of the victim but the same was done in self-defense; 2. Affidavits of accused, Greg Fajardo and Alfredo Golez Purpose: to prove that they were at the place where the crime was committed but have no participation thereof; 3. Medical Report issued issue d by Dra. Cielo F. F. Eltonn, M.D. to Gabriel Salas Purpose: to prove that the accused sustained several wounds as a result of the aggression by the victim; 4. Blotter Report of Molo Police Station (ICP-PP4)

Purpose: Purpose: to prove that the accused Gabriel Salas voluntaril voluntarily y surrendered surrendered to the Police authorities.

 I S S U E S 

1. Whether or not the accused committed the crime charged; 2. Whether or not they were guilty thereof.

W I T N E S S E S 

1. Accused Accused Gabrie Gabriell Salas Salas to testif testify y on the matter matters s and circum circumsta stance nces s attending the killing of the victim; 2. Accus Accused ed Alfre Alfredo do Gole Golez z and and Greg Greg Fajar ajardo do to testi testify fy on thei theirr nonnonparticipation on the killing; 3. Witness Jason Pilas-Pilas to testify on the exchange of words and blows between between the accused accused Gabrie Gabriell Salas Salas and the decease deceased d which which resulte resulted d to the death of the victim; 4. Dra. Cielo F. Eltonn, M.D. to testify on the veracity of the findings stated in the medical report of Gabriel Salas.

TRIAL RI AL DATE DA TES  S 

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

RESPECTFULLY SUBMITTED.

Iloilo City, Iloilo, Philippines, June 2, 2008

GALLEGO-SABIDO LAW OFFICES

Arguelles St., Jaro, Iloilo City By:

RHONALYN C. GALLEGO

Counsel for the Defense Roll No. 68999 / 5-2-07 IBP. IBP. No. 789084 / 12-29-07 MCLE Compliance No. 890590 / 12-20-07 PTR No. 345667 / 01-05-08

And

EVANGELINE S. SABIDO

Counsel for the Defense Roll No. 69009 / 5-2-07 IBP. IBP. No. 789085 / 12-29-07 MCLE Compliance No. 890591 / 12-20-07 PTR no. 345668 / 01-05-08

Copy furnished: PROS. SHYR PHOEBE F. REGUETA

Assistant City Prosecutor Ramon Q. Avanceña Hall of Justice Bonifacio Drive, Iloilo City

Received by:___________ Date: ___________

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