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REPUBLIC OF THE PHILIPPINES

National Capital Judicial Region


Regional Trial Court
Branch , Manila

PEOPLE OF THE PHILIPPINES,


Plaintiff-Appellant

- versus - CRIM CASE NO. 057270-CR


FOR: RECKLESSIMPRUDENCE
RESULTING TOSERIOUS
PHYSICAL INJURIES AND CAUSING
DAMAGE TO PROPERTY

MICHAEL LABIANA y MURRIERA,


Accused-Appellee

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APPELLANT’S BRIEF

Plaintiff-Appellant, thru the undersigned counsel, most respectfully

submit to this Honorable Court his brief for the appellant.

PREPARATORY STATEMENT

The case displays an apparent misapprehension of facts which was

committed against the plaintiff-appellant to the prejudice of his rights.

The Honorable Metropolitan Trial Court in its decision April 17, 2018

favored the averments of the accuse on the basis of the defense’s evidence
which made the court to believe that the accusations against the former was

without basis and the elements of which was not proven without reasonable

doubt.

The Court made pronouncements in the case brought forth, thus:

“After a careful evaluation of the evidence pro and con of the

parties, the court finds that the prosecution has failed to prove the guilt of the

accused beyond reasonable doubt... Although the private complainant was able

to prove that he suffered physical injuries and damage to property, he has

failed to prove that the damage he suffered was due to the negligence of the

accused, thus he cannot recover from the accused"

THE PARTIES