Pre-trial Guide

People vs. Bandoquillo

Stipulations:

1. Jurisdiction over the person of the accused Bandoquillo.

2. Identity of the parties.

Theory of the Case:

On or about the 4th day of February 2019, Accused Mark Anthony

Bandoquillo and Ryan Paul Samson had carnal knowledge of the Private
Complainant while the latter was deprived of reason or otherwise unconscious at the
boarding house of Joenary Villanueva situated in Prk. Paho Dos, Brgy. Estefania,
Bacolod City.

Admissions:

1. Will the defense admit that Accused Bandoquillo met for the first time the
Private Complainant at the boarding house of Joenary Villanueva located in
Prk. Paho Dos, Brgy. Estefania, Bacolod City.

2. Will the defense admit that Accused Ryan Paul Samson introduced Accused
Bandoquillo to the Private Complainant.

3. Will the defense admit that Accused Bandoquillo, Accused Ryan Paul Samson
and Joenary Villanueva had drinking session with Private Complainant on
February 04, 2019 at the boarding house of Joenary Villanueva.

4. Will the defense admit that Accused Bandoquillo smoked “shabu” together
with Joenary Villanueva during the aforesaid drinking session with the Private
Complainant.

5. Will the defense admit the existence and due execution of Police Blotter
Incident Report with IRF entry no. 068104-201902-0027 dated February 07,
2019.

6. Will the defense admit the existence and due execution of Police Blotter
Incident Report with IRF entry no. 068104-201902-0027 dated February 11,
2019.

7. Will the defense admit the existence of the Medical Certificate dated February
12, 2019 of Dr. Edwin Miraflor Jr., the OIC Medico Legal Office of Bacolod
City.

Issues:
 i. Whether or not the Accused is guilty of the Crime of Rape punishable
under Article 266-A, paragraph (a) and (b) of the Revised Penal Code.

ii. Whether or not the Accused is civilly liable for the Crime of Rape.

Documentary Exhibits

Exhibit 1 – Police Incident Report dated February 07, 2019.

Exhibit 2 – Police Incident Report dated February 12, 2019.
Exhibit 3 – Affidavit of Ferdjohn Irwin V. Cruz
Exhibit 4-1 to 4-8 – Facebook Message Screen Shot of the Private
Complainant’s conversation with Ferdjohn Irvin V. Cruz.

Reservation

Testimonial Evidence

1. The Private Complainant

2. Ferdjohn Irwin V. Cruz