Republic of the Philippines

National Capital Judicial Region

REGIONAL TRIAL COURT
Branch 83
Quezon City

PEOPLE OF THE PHILIPPINES, CRIMINAL CASE NO._______

Plaintiff, FOR:
RAPE
- versus -

Y,
Accused.
x-----------------------------------------------x

PRE-TRIAL BRIEF OF THE PROSECUTION

THE PEOPLE OF THE PHILIPPINES, through the undersigned City Prosecutor,

before this Honorable Court, most respectfully submit this Pre-Trial Brief:

SUMMARY OF ADMITTED FACTS

AND PROPOSED STIPULATION OF FACTS

The following are the admitted facts:

1. the identities of the person charged in the information and that of the person
arraigned are one and the same;

2. the identity of X, the victim;

3. the date, time, and place of the commission of the crime.

EVIDENCE FOR MARKINGS

1. Affidavit of the street sweeper A

Purpose: to prove that she was on duty on the street adjacent to Ys house when the
rape took place and that she heard shouting and other noises evincing a physical
struggle;

2. Affidavit of accuseds neighbor B

Purpose: to prove that she was tending to her plants next to the firewall bordering her
house with Y and that she heard a woman shouting and begging a man to stop the act
of sexual congress;
 3. Affidavit of neighborhood watch volunteer CCTV coordinator C
Purpose: to prove that he was on his station at the neighborhood watch CCTV
command center who then saw on one of the monitors Y forcefully dragging X by the
waist to his house;

4. CCTV footage of commission of the crime

Purpose: to prove that X dragged Y to his house, where the crime was committed;

ISSUES

1. Whether or not the accused committed the crime charged;

2. Whether or not he is guilty thereof.

WITNESSES

1. A to testify that she was on duty within the vicinity when the crime took place.

2. B to testify that she was next to her firewall tending to her plants when she heard
Y shout to stop X from raping her as well as other noises indicating a physical
struggle.

3. C to testify that he was manning his station at the Neighborhood Watch CCTV
Command Center and that his assigned area includes the street where X lives.

TRIAL DATES

Specifically all Fridays of the month, with the regular appearance of the undersigned
city prosecutors before this Honorable Court.

RESPECTFULLY SUBMITTED.
Quezon City, NCR, Philippines, July 21, 2017.

QUEZON CITY PROSECUTORS OFFICE

Quezon City Hall of Justice
Diliman Quezon City

By:
 JOHN DOMINIC T. BUHANGIN
Assistant City Prosecutor
Roll No. XXXXX / X-X-XX
IBP. No. XXXXXX / XX-XX-XX
MCLE Exempt
PTR Exempt

And

RAMON G. NICOPIOR
Private Prosecutor
Roll No. XXXXX / X-X-XX
IBP No. XXXXXX / XX-XX-XX
MCLE Exempt
PTR Exempt

Copy furnished:

ATTY. Z
Counsel for the Defense
Address
Address
Address

Received by:___________
Date: ___________