REPUBLIC OF THE PHILIPPINES

FIFTH JUDICIAL REGION

MUNICIPAL TRIAL COURT IN CITIES
DARAGA, ALBAY

KIRSTEN C. SAZON

-versus- For Collection of based

Bouncing Checks with
Damages

GABRIELLE CJ LAGRIMAS
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PRE-TRIAL BRIEF OF THE DEFENSE

DEFENDANT, by counsel and through this Honorable Court,

respectfully submits this pre-trial court’s order dated, June 26, 2024.

I. SUMMARY OF ADMITTED FACTS, PROPOSED STIPULATION OF

FACTS AND DEFENSES

The defendant hereby admits the following facts:

I.1. The identity of the private complainant, Kirsten Sazon;
I.2. The date of the commission of the offense;
I.3. Describe the loan amount, ₱1,000,000.00 with an interest rate
of ₱14,000 per year, as stated by the private complainant;

Furthermore, the defendant respectfully proposes the following facts:

I.4. That the defendant already paid the obligation of the
amount covered by the checks after the complainant
demanded the money.
I.5. That the defendant has no knowledge or information on the
issuance of said dishonored checks since no notice of
dishonored was presented to the defendant.

The defendant, moreover, raises the following defenses:

I.6. That Kirsten Sazon, despite the promise to pay to the

defendant, continued to harass and damage the reputation of
the defendant on social media. As a result, the defendant
suffered mental anguish, shock, sleepless nights, and severe
anxiety.
I.7. That the obligation to pay was already extinguished before the
complainant filed her complaint against the defendant.

II. EVIDENCE FOR MARKINGS

II.1. The sworn affidavit of Jessalyn Renolayan.

Purpose: To attest that the defendant already paid his obligation
to the complainant.

II.2. The paid-in-full letter.

Purpose: To prove that the defendant paid his obligation in full to
Kiertsan Sazon, the complainant’s sibling as the receiver.

III. ISSUE

III.1. Whether or not the defendant is justified in committing the

crime charged.

IV. WITNESSES

IV.1. Jessalyn Renolayan is to testify on the contents of her

sworn affidavit and strengthen the defendant’s claim that
the defendant already paid his obligations to the
complainant. Thus, proving the defendant’s good faith and
pure intention.

V. TRIAL DATES

Specifically, all Fridays of the month, with the regular appearance

of the undersigned counsel before this Honorable Court.

RESPECTFULLY SUBMITTED.
Daraga Albay, Philippines, June 24, 2024

ATTY. AYA MARQUEZ- CORTEZ

Counsel for the Defendant
Yap Bldg., Rawis, Legazpi City
Roll No.: 12468
PTR No.: 1112345 06-27-2019 Legazpi City
IBP No.: 176184 06-27-2017 Legazpi City
MCLE Compliance No.: 547623 05-18-2017
Copy furnished:

NADINE ESPELA
Assistant City Prosecutor
Office of the City Prosecutor of Legazpi
Legazpi City

Received by:________________
Date:_________________