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Republic of the Philippines

REGIONAL TRIAL COURT


10TH Judicial Region
Branch 9
Malaybalay City, Bukidnon

PEOPLE OF THE PHILIPPINES,


Complainant, CRIM. CASE NO. 80781-08

-versus-

FOR: SLIGHT PHYSICAL


JURIS GECKO Y PRODENS INJURIES
Accused,
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 admitted facts:


1. The identity of the one charged in the information and that arraigned
are one and the same;
2. The identity of Joben S. Dito, the victim;
3. The injury caused to the victim;
4. The date and places of the commission of the crime.

EVIDENCE FOR MARKINGS

1. Affidavit of the complainant, Joben S. Dito


Purpose: to prove that he was in the presence of the accused when and how
he sustained his injuries and who did the same.
2. Affidavit of the neighbor, Richard Amba
Purpose: to prove that he was at the scene when the incident occurred and
that he saw the accused inflict the injuries to the victim.
3. Medical Certificate issued by a Rural Health Physician
Purpose: to prove that the injuries sustained by the victim have caused him
to be incapacitated for 9 days.

ISSUES

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


2. Whether or not they were guilty thereof.

WITNESSES

1. Joben S. Dito to testify about the when and how he sustained the
injuries and who inflicted them;
2. Richard Amba to testify that he was there when the incident
happened;
3. Dr. Susan Marie Punongbayan to testify that she conducted the
medical examination of Joben S. Dito and to attest to the veracity of
her findings in the said certificate.

TRIAL DATES

Specifically all Tuesdays of the month, with the regular appearance of


the undersigned city prosecutors before this Honorable Court.

RESPECTFULLY SUBMITTED.

Malaybalay City, Bukidnon, Philippines, April 3, 2017.

MALAYBALAY CITY PROSECUTORS OFFICE


Hall of Justice
Capitol Compound, Malaybalay City

By:

GLADYS A. BIOYO
Assistant City Prosecutor II
Roll No. 2345/ 2/2/09
IBP No. 34797/ 2/03/17
MCLE Exempt
PTR Exempt

MANU A. PAGUE
Assistant City Prosecutor I
Roll No. 8789/ 3/2/10
IBP No. 675847/ 1/23/17
MCLE Exempt
PTR Exempt

Copy furnished:

ZYJAN B. ARANAYDO
Counsel for the Defense
Brgy. 5, Malaybalay City

Received by: ________________


Date: _____________________