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Republic of the Philippines Sixth Judicial Region

REGIONAL TRIAL COURT


Branch___
Pasay City

PEOPLE OF THE PHILIPPINES, CRIMINAL CASE NO._______


Plaintiff, FOR: RAPE

- versus –

ERICK JOHN PAUL PILI SAYSAY,


Accused.

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

PRE-TRIAL BRIEF OF THE ACCUSED

ACCUSED, through the undersigned counsel, before this Honorable Court, most
respectfully submit this Pre-Trial Brief:

SUMMARY OF ADMITTED FACTS AND PROPOSED STIPULATION OF FACTS

The accused admit the following:


1. The identity of the person charged in the complaint and that of the person arraigned is one
and the same;
2. The identity of Ma. Consorcia Golea, the victim;
3. The meeting of the victim and her father on 10 January 2019 in the accused’s office for the
execution of a contract;

EVIDENCE FOR MARKINGS

1. Airline ticket
Purpose: To prove that the accused left Manila on 18 January 2019 bound to Dipolog city.
2. Certification of Philippine Airlines
Purpose: To prove that the accused was boarded PR 165 bound to Dipolog on 18 January
2019.
3. Photograph of the accused welcomed by constituents
Purpose: To prove that the accused was in Dipolog City on 18 January 2019.
4. Photograph of the accused with Mayor ERIKA B. JUMALON
Purpose: To prove that the accused was in Dipolog City on 18 January 2019.
5. Affidavit of Mayor ERIKA B. JUMALON
Purpose: To prove that the accused was in Dipolog City on 18 January 2019.
6. Photographs of accused and Ms. AVA S. TENDENILLA;
Purpose: To prove that the accused was in Dipolog City on 19 January 2019.
7. Affidavit of Ms. AVA S. TENDENILLA;
Purpose: To prove that the accused was in Dipolog City on 19 January 2019.
8. Affidavit of Ms. KATRINA S. LOZANO
Purpose: To prove that accused was in Dipolog City on 20 January 2019.
9. Photograph of accused attending the Brgy. Fiesta at Brgy. San Pedro
Purpose: To prove that accused was in Dipolog City on 20 January 2019.
10. Airline Ticket
Purpose: To prove that the accused was on board PR 165 bound to Manila on 25 January
2019.

ISSUES

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

WITNESSES

1. Accused Erick John Paul Pili Saysay to testify on the matters and circumstances attending
the raping of the victim;
2. Witnesses Erika B. Jumalon, Celine P. Golberg and Katrina S. Lozano to testify on the
presence of the accused was in Dipolog City;
3. Witness Celine S. Go to testify on the absence of the accused at No. 100, Shell Residences,
Pacific Drive, Sunset Avenue, Pasay City on January 19, 2019.

T RIAL DATES

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

RESPECTFULLY SUBMITTED.

LIANNE MEREDITH T. GUMTANG


Assistant City Prosecutor
Appointment No. A-000 (2017-2019)
Until December 31, 2019
PTR No.: 123456, 01-02-2019 Pasay City
IBP No.: 10000000, 01-02-2019Pasay City
MCLE Compliance No. : V-000134454 January 15, 2019
Roll No.: 501235
16th Floor Unit 1610 The Great Tower, Malate Manila

Doc. No. : 10;


Page No. : 123;
Book No. : 8;
Series of 2019.