REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

7th Judicial Region
Branch 7,
Cebu City

PEOPLE OF THE PHILIPPINES,

Complainant,
CRIMINAL CASE NO. 12345
- versus -
FOR: RAPE BY SEXUAL ASSAULT
GIANCARLO LARGO,
Accused.
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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 the admitted facts:

1.The identity of the one charged in the information and that of the person
arraigned are one and the same;

2.The identity of AAA, the private complainant;

3.That the private complainant is a scholar under the University’s Scholarship

Program of the University of San Carlos;

4.That the private complainant is a varsity player of the University Junior’s

Basketball Team of the University of San Carlos;

5. That the private complainant is a Grade 10 student of the accused in the

University of San Carlos;

6.That Dr. Lana Meneses is an expert in the medical field and competent to
conduct a medical examination on the victim;

7.That SPO1 Ritchie Tejana is the police officer of the Fuente Police Station of
the PNP as Women and Children Protection Desk (WCPD) Officer who
prepared the police report issued on February 16, 2017;
8. That the accused consented to the use of Judicial Affidavits in lieu of direct
testimonies; and

9.That this Honorable Court has jurisdiction to hear and try this case;

EVIDENCE FOR MARKINGS

1. Certificate of Live Birth authenticated by the PSA

Purpose: to prove that the victim is a minor

2. Police Report prepared by SPO1 Ritchie Tejana, issued on February 16, 2017
Purpose: to prove that on said date, the victim reported the incident to the police

3. Signature of SP01 Ritchie Tejana in his Judicial Affidavit

Purpose: to authenticate the signature in the Judicial Affidavit

4. Medical Examination Report prepared by Dr. Lana Meneses on February 16,

2017
Purpose: to prove that there was a recent anal penetration on the victim

5. Conclusions in the Medical Examination Report prepared by Dr. Lana

Meneses on February 16, 2017
Purpose: to prove that there was a recent anal penetration on the victim

6. Signature of Dr.Lana Meneses in her Judicial Affidavit

Purpose: to authenticate the signature in the Judicial Affidavit

7. Affidavit of the victim, AAA, executed on February 17, 2017 before Atty.
Quennie Kate Adan
Purpose: to prove that on February 14, 2017, the accused inserted his penis in
the anal orifice of the victim against the latter’s will

8. Affidavit of SPO1 Ritchie Tejana, executed on February 17, 2017 before

Atty. Jewel Jade Famor
Purpose: to prove that the victim reported the incident to the police

9.Affidavit of Dr. Lana Meneses, as an expert witness, executed on February

17, 2017 before Atty. Rheswi Grace Colina
Purpose: (1) to prove that there was a recent anal penetration on the victim and
(2) that the victim was raped

ISSUE

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

WITNESSES
1. AAA to testify that on February 14, 2017, the accused had anal sex with the
victim inside the University of San Carlos- North Campus against the latter’s
consent;

2. Dr. Meneses, Lana to testify on the medico-legal report and to prove that the
findings of the medical report are consistent with the history of recent anal
penetration; and

3. SPO1 Tejana, Ritchie to testify that the victim reported the incident.

TRIAL DATES

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

RESPECTFULLY SUBMITTED.

Cebu City, Cebu, Philippines, March 15, 2017.

Atty. Irene Sanoria

Roll No. 1235
IBP Lifetime No. 9663
MCLE Compliance No. 123461-17
PTR No. 1234-12

Copy furnished:

Ima Rae M. Doverte

Counsel for the Defense
DTB Law Office ABS Building
i2 IT park, Cebu City

Received by:___________
Date: ___________