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PEDRO CARGO,
Accused,
X-----------------------------X
P R E T RI A L B R I E F
COMES NOW, the ACCUSED PEDRO CARGO, through the
undersigned counsels and unto this Honorable Court, most respectively
submits his Pre-Trial Brief in the above-entitled case, to wit:
I.
3.) That the accused Pedro Cargo, told Kris Pilapil that he witnessed
Rex Ayala and Danila Taclob having Sexual Intercourse on the
bedroom of the spouses on the night of March 12, 2013 .
4.) That the accused Pedro Cargo was Terminated from employment
on March 15, 2013 by Rex Ayala.
5.) After the accused Pedro Cargo was terminated from the
Employment of the Ayala Household, He was hired by Henry Tan
on March 24, 2013 to be the latters designated driver.
6.) That on December 20, 2013 at around 5 am, the accused Pedro
Cargo together with his wife boarded flight PR 822 from Davao to
Manila as evidenced by his boarding pass.
7.) That on December 20, 2013, at around 10 am, the accused Pedro
Cargo and his wife checked into the Bernardos Hotel Batanes.
8.) That on December 22, 2013, the accused Pedro Cargo and his wife
arrived in Davao from Batanes via Manila.
9.) That on December 23, 2013 at around 8.30 pm, the accused Pedro
Cargo, received a call from his employer, Henry Tan, instructing
him to go to Victoria Plaza Mall, located at Bajada Davao City,
enter the Toyota Vios car parked in said location and drive it to
Damosa Gateway Lanang, Davao city.
10.) That on December 23, 2013 at around 11pm, while the accused
Pedro Cargo was parked in Damosa Gateway, Lanang Davao City,
the police apprehended him.
hours before the flight) to catch his 8:00 a.m. flight to Batanes. The
Plane left Davao for Manila around 5:00 a.m. in the morning.
3.) PAL Baggage Tag for PR 822 from Davao bound to Manila
marked as EXHIBIT 3 to prove that accused was really inside
the Airport and was sure to board his flight given that his baggage
was already checked in.
IV.
V.
1.) Accused PEDRO CARGO himself to testify as to the material facts of the
case. That on December 20, 2013, he was at Bernardos Hotel in Batanes.
That he had no knowledge of the kidnapping of Jason Ayala. That on the
night of December 23, 2013 he merely followed the instructions of his
current employer, Henry Tan.
2.) MARY TANSECO, manager of Bernardos Hotel Batanes, to testify that
the accused was at Bernardos Hotel Batanes at the following dates. Said
MARY TANSECO would also testify as to the authenticity of the Official
receipt marked EXHIBIT 1 and that it was indeed Bernardos Hotel
Batanes that issued the aforementioned official receipt.
3.) KRIS PILAPIL, a kasambahay working in the Ayala Household, to
testify that she has personal knowledge of an affair between Danila Taclob
4
and Rex Ayala Said KRIS PILAPIL, would also testify that she and the
Accused Pedro Cargo had a conversation dated March 13, 2013 and that the
accused Pedro Cargo told her that he, the accused Pedro Cargo, had
discovered the affair between Danila Taclob and Rex Ayala.
Assisted by:
Alain Jan B. Brigoli
PTR No. 43215678
IBP No. 938475
Roll No. 34562
MCLE Compliance Cert No. II -9876523
Ralph Palmera
PTR No. 3847563
IBP No. 234512
Roll No. 94856
MCLE Compliance Cert No. II -6543879
Guian Cuaterno
PTR No. 75869374
IBP No. 231789
Roll No. 76543
MCLE Compliance Cert No. II -1657895
Copy Furnished:
JESSIELLE ANN C. FABIAN
Assistant City Prosecutor