Republic of the Philippines

REGIONAL TRIAL COURT

QUEZON CITY
Branch

PEOPLE OF THE PHILIPPINES,

Complainant,

- versus – Criminal Case No. XXXXXXXXX

For: Violation of Article 171 of
the Revised Penal Code

XXXXXXXXXXXXXXX
Accused.
X---------------------X

PRE-TRIAL BRIEF FOR THE ACCUSED

Accused, DANTE TORRES, through undersigned counsel

and unto this Honorable Court, respectfully state: THAT-

I. PROPOSED STIPULATION OF FACTS.

1. That the accused was actually the one who solemnized

the XXXXXXXXXXXX;

2. That the accused is the signatory in the Marriage

Certificate XXXXXXXX;

II. DOCUMENTARY EXHIBITS

3. Sinumpaang Salaysay of XXXXXXXXXXX;

4. Sinumpaang Salaysay of XXXXXXXX

5. The Marriage Certificate of XXXXXXXX;

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 6. Accused herein reserve his right to present additional
documentary evidence during the trial.

IV.ISSUES TO BE RESOLVED

7. Whether or not Accused violated Par. 4 of Article

171 of the Revised Penal Code.

V.NUMBER OF WITNESSES TO BE PRESENTED

8. XXXXX;

9. XXXXX;

10. XXXXX;

11. Accused herein reserve his right to present other

witnesses during the course of the trial.

VII. LAWS APPLICABLE

12. The pertinent provisions of the Revised Penal Code of

the Philippines, the Revised Rules of Court and the established
jurisprudential precepts laid down by no less than the Supreme
Court of the Philippines.

VIII. AVAILABLE TRIAL DATES

13. To be agreed upon by the parties taking into

consideration the calendar and to the dates most convenient to
this Honorable Court.

RESPECTFULLY SUBMITTED.

City of Manila for Quezon City, XXXXXX 2018.

BY:
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 Jose Manambang
Counsel for Accused
Roll No. 68sss
IBP No. Pasig City
PTR No. Manila City
MCLE Compliance: Exempted pursuant
to MCLE Governing Board Order No.
1, s. 2008

Copy furnished:

THE BRANCH CLERK OF COURT (Through Personal Service)

Quezon City

OFFICE OF THE PROSECUTOR (Through Registered Mail)

Quezon City

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