Republic of the Philippines

First Judicial Region

REGIONAL TRIAL COURT
Branch IV
Baguio City

PEOPLE OF THE PHILIPPINES,

Complainant,

-versus- Criminal Case No. 20-CR-11057

For: Slight Oral Defamation

CHESKA L. BAUTISTA,
Respondent
x-----------------------------------x

PRE-TRIAL BRIEF

THE PEOPLE OF THE PHILIPPINES, through the undersigned

counsel, most respectfully submits this Pre-trial Brief and states the
following:

I. POSSIBILITY OF AMICABLE SETTLEMENT:

The Complainant is willing to have this case settled under

such terms and conditions the parties may find beneficial to agree.

II. BRIEF STATEMENT OF THE CASE

a. Complainant is a Daycare Center teacher at Trancoville,

Baguio City.
b. On December 20, 2019, Complainant was heading home
when she met the respondent in front of the house of Abe
Dela Cruz;
c. Respondent has thrice uttered the following words to the
complainant, to wit “““PUTA KA CASSANDRA! INAGAW MO
ASAWA KO, PALAGI KAYONG NAGLALANDIAN SA
ILALIM NG BAHAY NAMIN” (“You are a whore! You stole
my husband! You are always flirting with each other under
our house”);

III. ADMITTED FACTS

All allegations indicated in the pleadings submitted by the plaintiff.

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 IV. PROPOSED ISSUE TO BE RESOLVED

Whether there is a malicious intent on the imputations of respondent

tending to cause dishonor, discredit, or contempt of the complainant.

V. LIST OF EXHIBITS
a. EXHIBIT “A” – Certificate to File Action
PURPOSE: To satisfy a condition precedent for the filing of this action.

b. EXHIBIT “B” – Resolution of the Investigating Prosecution

PURPOSE: To prove that the crime has been committed and the respondent is probably guilty thereof.

c.EXHIBIT “C” – Complaint-Affidavit of Cassandra Santos

d.

For the defense:

a.EXHIBIT 1: Judicial Affidavit of
EXHIBIT “A” – Cellphone Video taken by Abe dela Cruz.

PURPOSE: To prove how the Respondent uttered the

defamatory words against the Complainant.

a. EXHIBIT “B” – Judicial Affidavit of Michelle Espique.

PURPOSE: To prove that the Complainant was in school

during the alleged time she was with the Respondents’
husband and that the Respondent uttered the words
complained of.

b. EXHIBIT “C” – Judicial Affidavit of Abe dela Cruz.

PURPOSE: To prove that the respondent has thrice uttered the

words complained of.

c. EXHIBIT “D” – Certificate to File Action

PURPOSE: To prove that there was compliance with the

Barangay conciliation pursuant to the Revised Katarungang
Pambarangay Law before filing of complaint before this
honorable court.

VI. WITNESSES TO BE PRESENTED

a. Cassandra E. Santos
b. Abe Dela Cruz
c. Michelle N. Espique

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 VII. RESERVATION
Complainant respectfully reserve the right to present additional
oral and documentary evidence as may become necessary in the
course of the trial.

VIII. TRIAL DATES

February 21, 2020; February 28, 2020

PRAYER

WHEREFORE, in view of all the foregoing, Complainant

through the undersigned counsel respectfully prays that the Court
note this pre-trial brief.

Baguio City, Philippines, this 3rd day of February 2020.

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