Republic of the Philippines

National Capital Judicial Region

Regional Trial Court
Branch ___
Pasay City, Metro Manila

PEOPLE OF THE PHILIPPINES,

Plaintiff , Criminal Case no.:______
-versus- For: Murder

RONALD OCAMPO,
Accused,

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PRE-TRIAL BRIEF
Defendants, for counsel respectfully submits that:

I. SUMMARY OF ADMITTED FACTS AND PROPOSED STIPULATION OF

FACTS

The accused admitted and proposed the following facts:

a) The identity of the person charged in the information;
b) The killing of the victim;
c) The date, place and time of the killing;
d) That the accused should not have been prosecuted for the crime of murder;
e) That the accused acted in self-defense; and
f) That the accused be entitled to the following mitigating circumstances :
i. voluntary surrender
ii. Passion and obfuscation

II. ISSUE
Whether or not the accused in this case guilty beyond reasonable doubt of the offense
charged in the information.
 III. EVIDENCE FOR THE DEFENSE

a. Documentary evidence

No. Document Purpose

A Affidavit of accused, Ronald
Ocampo
B Affidavit of Granny Ocampo
C Affidavit of Nunoy
D Blotter report
To prove that he admits the killing of the
victim but the same was done in self
defense
To prove prior occurrence to the killing
To prove that the accused and victim had
an altercation before the killing
To prove voluntary surrender

***The defense reserved the right to mark additional exhibits during the course of the
trial.

Testimonial evidence (witnesses)

No. Document Purpose

A Ronald Ocampo To testify on the matters and
circumstances attending the killing of the
victim
B Granny Ocampo To testify on what transpired prior to the
killing
C Nunoy To testify on the exchange of words and
blows between the accused and deceased
which resulted to the death of the victim.
***The defense reserved the right to present additional testimonial witnesses during the
course of the trial.
 PRAYER
WHEREFORE, defendant prays that pre-trial brief be noted and admitted.

RESPECTFULLY SUBMITTED.

8 Feb 2019, Pasay City Atty Jefferson Pingol

Counsel for Defense
Group One Defense Attorneys Law Office
2452 Donada St., Brgy 32, Pasay City
Copy Furnished:

Diego Salvador Aligno

Branch Clerk Court of Regional Trial Court Branch __

Atty. John Michael Moralejo

Public Prosecutor
Explanation

The foregoing pre-trial brief is being served by registered mail due to lack
of personnel to effect personal service.

Atty Jefferson Pingol

Counsel for Defense
Group One Defense Attorneys Law Office
2452 Donada St., Brgy 32, Pasay City