Republic of the Philippines

REGIONAL TRIAL COURT

NATIONAL CAPITAL JUDICIAL REGION
MAKATI, BRANCH 15
PEOPLE OF THE PHILIPPINES,
Plaintiff,
-versus-

(I.S. No. 001-2014)

Case No. 01
For: RAPE

ALLAN HABER,
Accused.
x-------------------------------x
PRE-TRIAL BRIEF
COMES

NOW

the

public

prosecutor

thru

the

undersigned counsel in the above-entitled case and to the

Honorable Court respectfully submits this pre-trial brief;
I. For purposes of Plea Bargaining
The Prosecution is not submitting any proposal for
plea bargaining.
II. For purposes of Stipulation of Facts
1. The identity of the accused in the information and
that of the person arraigned are one and the
same;
2. The identity of Renalyn Santiago, the victim; and
3. The date and places of the commission of the
crime.
III. Documentary and Object Evidence
Exhibit A Complaint-Affidavit of Renalyn
Santiago dated May 5, 2014
Exhibit B Medico Legal Report conducted in
Ospital ng Makati dated May 2, 2014
Exhibit C Police Report (Makati City Police
Station) dated May 1, 2014
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Exhibit D Complainants school identification

card
Exhibit E Complainants Certificate of
Employment
Exhibit F Affidavit of witness Sharon Sy
Exhibit G Complainants stained underwear
Exhibit H Complainants bed sheet
IV. As to Witnesses:
1. Private Complainant Renalyn Santiago
2. Dr. Merideth Lim, Medico Legal or Attending
Physician of the Private Complainant
3. Sharon Sy, complainants board mate
V. On Trial dates
Private prosecution needs at least 2 (two) trial
dates to complete the presentation of evidence, the
dates to be set within the conformity of the defense
and the Honorable Court during the Pre-Trial
Conference.
Makati, Philippines this 12th day of May, 2014.

Charmaine J. Itable
City Prosecutor
THE CLERK OF COURT
RTC, Makati
Please submit the foregoing Pre-Trial Brief for the
consideration and approval of the Honorable Court.
Charmaine J. Itable
City Prosecutor
IBP No. 082956; 04/24/12 Makati
City
PTR No. 65956; 02/25/12 Makati
City
Roll No. 21455; 03/27/11
MCLE No. 128567; 03/15/13
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Copy Furnished:
Atty. Ryan Alteria
Counsel for Defendant
Alteria Law Office
1515 C.M. Recto Avenue, Manila
By registered mail:
Explanation: Due to lack of personnel to effect personal
delivery, this pleading is sent through registered mail.