Pre-Trial Brief SAMPLE

REPUBLIC OF THE PHILIPPINES
SIXTH JUDICIAL REGION

MUNICIPAL TRIAL COURT IN CITIES
BACOLOD CITY
BRANCH 001
PEOPLE OF THE PHILIPPINES
-versus-
FOR: Slight Physical Injuries

Article 266 of the Revised
Penal Code
RUFINA L. CALIWAN
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 identity of person charged in the information and that of
the persons arraigned are one and the same;
2. the identity of Rhodora Pasilona, the victim;
3. the physical injury inflicted on the victim;
4. the date and places of the commission of the crime.
EVIDENCE FOR MARKINGS
1. Affidavit of the Barangay Kagawad Junny Dip
Purpose: to prove that after the conciliation proceedings at the
Barangay, Rufina Caliwan physically aggressed and inflicted injury to
Rhodora Pasilona;
2. Notice of Hearing for Conciliation issued by the Office of the
Punong Barangay of Barangay Malinong Village
Purpose: to prove that there was scheduled a conciliation
proceeding
3. Affidavit of Ofelia Ocampo
Purpose: to corroborate the testimony of Junny Dip
4. Police Blotter issued by Bacolod City Police Station
Purpose: to prove that the police authority received a report that

a physical altercation took place at the Barangay Hall of Barangay
Malinong Village ;
5. Medical Certificate issued by Corazon Locsin Montelibano
Memorial Hospital
Purpose: to prove the extent of the injury of the victim
ISSUES
1. Whether or not the accused committed the crime charged;
2. Whether or not they were guilty thereof.
WITNESSES
1. Junny Dip to testify that a physical altercation took place and
that Rufina Caliwan inflicted physical injury to victim;
2. Ofelia Ocampo to testify that she and Rufina Caliwan were
together for a conciliation proceeding at the Barangay after which the
crime happened;
3. Dr. Hayden Mho to testify that he attended to Rufina Caliwan
during her admission at Corazon Locsin Montelibano Memorial
Hospital and as well as the extent of her injury;
6. Police Officer II Sixto Six to testify that he received the
reports and conducted an investigation thereafter;
TRIAL DATES
Specifically all Fridays of the month, with the regular
appearance of the undersigned city prosecutors before this
Honorable Court.
RESPECTFULLY SUBMITTED.
Bacolod City, Philippines, March 2, 2015.
Angelina Dioly
Assistant City Prosecutor
Roll No. 67890 / 5-2-07
IBP. No. 667899 / 12-29-07
MCLE Exempt
PTR Exempt
Copy furnished:
FELIMON SY
13F Kung Sin O Bldg.

No. 69, Mabilog Rd.
Bacolod City
Received by:___________
Date: ___________
REPUBLIC OF THE PHILIPPINES

SIXTH JUDICIAL REGION
MUNICIPAL TRIAL COURT IN CITIES
BACOLOD CITY
BRANCH 001
PEOPLE OF THE PHILIPPINES
-versus-
FOR: Other Light Threats

Article 285 of the Revised
Penal Code
RUFINA L. CALIWAN
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 identity of person charged in the information and that of
the persons arraigned are one and the same;
2. the identity of Rhodora Pasilona and Ofelia Ocampo, the
victims;
3. the verbal threat of inflicting harm to the victims;
4. the date and places of the commission of the crime.
EVIDENCE FOR MARKINGS
1. Affidavit of the Jenefer Ann Iston
Purpose: to prove that a commotion in the neighborhood
transpired and Rufina Caliwan verbally threatened of inflicting harm to
the victims;
2. Complaint of Ofelia Ocampo filed at Office of the Lupong
Tagapamayapa of Barangay Malinong Village
Purpose: to prove that the commotion between Ocampo,
Pasilona, and Caliwan was brought to the Barangay for
resolution
3. Police Blotter issued by Bacolod City Police Station
Purpose: to prove that the police authority received a report for

serious oral defamation which took place at Barangay Malinong
Village ;
ISSUES
3. Whether or not the accused committed the crime charged;
4. Whether or not they were guilty thereof.
WITNESSES
1. Jenefer Ann Iston to testify that a commotion in the
neighborhood transpired and Rufina Caliwan verbally threatened of
inflicting harm to the victims;
2. Police Officer II Sixto Six to testify that he received the
reports and conducted an investigation thereafter;
3. Kagawad Brent Donasco to corroborate the testimony of
Jenefer Ann Iston
TRIAL DATES
Specifically all Fridays of the month, with the regular
appearance of the undersigned city prosecutors before this
Honorable Court.
RESPECTFULLY SUBMITTED.
Bacolod City, Bacolod, Philippines, March 2, 2015.
Angelina Dioly
Assistant City Prosecutor
Roll No. 67890 / 5-2-07
IBP. No. 667899 / 12-29-07
MCLE Exempt
PTR Exempt
Copy furnished:
FELIMON SY
13F Kung Sin O Bldg.
No. 69, Mabilog Rd.
Bacolod City
Received by:___________
Date: ___________

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What are the charges being brought against Rufina L. Caliwan?

What evidence is being presented in each case?

REPUBLIC OF THE PHILIPPINES

SIXTH JUDICIAL REGION

FOR: Slight Physical Injuries

Purpose: to prove that the police authority received a report that

13F Kung Sin O Bldg.

REPUBLIC OF THE PHILIPPINES

FOR: Other Light Threats

Purpose: to prove that the police authority received a report for

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