Pre-Trial Brief For The Accused Sample

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Republic of the Philippines

11th Judicial Region


MUNICIPAL TRIAL COURT
Polomolok, South Cotabato

PEOPLE OF THE PHILIPPINES,


Plaintiff
CRIMINAL CASE NO.______
FOR: ESTAFA, under paragraph 2
-versus - of Article 315 of the Revised Penal
Code

FRANCESLY CAUBA,
Accused.
x-----------------------------------------------x

PRE-TRIAL BRIEF OF THE ACCUSED

ACCUSED, through the undersigned counsel, before this Honorable Court, most
respectfully submit this Pre-Trial Brief:

SUMMARY OF ADMITTED FACTS AND PROPOSED STIPULATION OF FACTS

The accused admit the following:

1. the identities of those charged in the information and that of
t h e 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.

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 by Dra. Cielo 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)

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