Republic of the Philippines

REGIONAL TRIAL COURT

First Judicial Region
Branch 4
Baguio City

FAMILY COURT OF BAGUIO CITY

PEOPLE OF THE PHILIPPINES, CRIMINAL CASE NO. 40417-R

Plaintiff,

- versus -
FOR: VIOLATION OF SEC. 10(a)
OF RA 7610
FLORA GAMBOC BOLLA,

x----------------------------------------------x

MOTION TO AMEND PRE-TRIAL ORDER

THE ACCUSED through counsel and unto this Honorable Court,
respectfully states the following:

1. That the Pre-Trial Conference for the present case was conducted
on May 16, 2017;

2. That the Pre-Trial Order was received by the accuseds counsel on

June 2, 2017;

3. That the Pre-Trial Order states that only Gretchell Aguilar, Michelle
Bolla and Merlyn Bugtong is to be presented by the defense as
corroborating witnesses;

4. However, in the interest of justice, the accused prays that the

Honorable Court amend the Pre-Trial Order to include additional
witnesses vital to the cause of the accused;

5. That the following are the persons the accused prays to be

included as witnesses to be presented during trial and the substance of
their testimony:

i. Khayla Wacal - to testify that she was at the accuseds house

almost everyday during the period from June 2016 to
December 2016 and that she was almost always with the
private complainant during their stay at the accuseds house;
that the private complainant knows the location of the key to
the house because the private complainant would be the one
to open the door to the house whenever she comes home first;
that she would play every afternoon with the private
complainant outside and that they would come home before it
got dark; and that she never saw or heard the accused locked
the private complainant out of the house as a kind of
punishment while she was staying at the accuseds home;
 ii. Pinky Lofranco - to testify that she stayed together with the
private complainant in the house of the accused during the
month of January 2017; that she was almost always with the
private complainant at the house of the accused whenever the
private complainant was not in school; and that she knows for
a fact that the private complainant knows the location of the
key to the house as the private complainant showed her the
location of the key; and

iii. David Dawa - that he is a Kagawad of St. Joseph Village Navy

Base, Baguio City, and that he regularly makes rounds at the
area at night and that he did not see the private complainant
wandering thereat from June 2016 until January 2017.

6. That these persons were not named during the Pre-Trial Conference
because Pinky Lofranco, who was then in Pangasinan recuperating from
a sickness, was not available at that time, and that Khayla Wacal and
David Dawa only agreed to testify after the Pre-Trial Conference;

7. That these witnesses are vital for the accused to disprove the
accusations made in the information, and that it will cause injustice
against the accused if she is denied the opportunity to present these
witnesses;

8. That the accused apologizes for this late addition of witnesses and
humbly prays for the Honorable Courts benevolence and grant this
instant motion in the highest interest of justice;

9. That this motion is not intended for delay or to prolong the

proceedings in this case but for reasons already stated above.

WHEREFORE, premises considered, the accused through counsel

prays that the Pre-Trial Order dated May 16, 2017 be amended to
include the following witnesses to be presented by the defense during
Trial: Khayla Wacal, Pinky Lofranco and David Dawa.

Other reliefs just and equitable under the premises are also prayed
for.

June 6, 2017, Baguio City, Philippines.

ATTY. LOUIE L. SANTOS

Counsel for the accused
Rm. 307 Jose Miguel Building
No.1 Labsan St., Baguio City
PTR No. 2953778, Baguio City
IBP No. 1061997, January 10, 2017
Roll No. 66431, June 22, 2016
 NOTICE OF HEARING

THE BRANCH CLERK OF COURT

REGIONAL TRIAL COURT
Branch 4
Baguio City
FAMILY COURT OF BAGUIO CITY

THE CITY PROSECUTORS OFFICE

Justice Hall, Baguio City

Greetings!

Please take notice that the undersigned counsel will submit the
foregoing motion for hearing on June 13, 2017 at 8:30 o'clock in the
morning or any time or date thereafter according to the availability of the
Court.

Thank you.

LOUIE L. SANTOS

Copy Furnished:

PROS. MARGARITA N. DE GUZMAN-MANALO

THE CITY PROSECUTORS OFFICE
Justice Hall, Baguio City