REPUBLIC OF THE PHILIPPINESNATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURTBRANCH 109, PASAY CITY

PEOPLE OF THE PHILIPPINES,

- versus – CRIM. CASE NO: 6572For: RAPE

JAYSON RAMOS y SANTOS1234 Sandejas St. Brgy 4, Pasay City (Detained)

Accused.x---------------------------------------x

PRE-TRIAL BRIEF OF THE PROSECUTION

THE PEOPLE OF THE PHILIPPINES, through the undersigned City Prosecutor, before the Honorable Court, respectfully submits this Pre-Trail Brief:

SUMMARY OF ADMITTED FACTSAND PROPOSED STIPULATION OF FACTS:

The following are admitted facts: accused were arrested o 1. That the accused were identified as JAYSON RAMOS.2. That the victim ABDUL RAFI ONOS, being born on September

20, 2003.3. That the Birth Certificate issued by the National Statistics

Office, attached herein as “Exhibit I” is authentic.4. That the incident was reported to the police on MARCH 21,

2014. 5. That the victim was examined by Dr. CRISANTA CHIANPIAN

of the Pasay General Hospital as evidence by a medico-legal certificate dated MARCH 22, 2014.

6. That the accused were arrested on MARCH 21, 2014 by the officers of Barangay Tanod immediately after the incident.

We respectfully request this Honorable Court that our evidence be marked as follows:

EVIDENCE FOR MARKINGS1. Exhibit “A” – Sinumpaang Salaysay of the Private Complainant.2. Exhibit “B” – Medico-legal certificate of examination conducted

by Dr. CRISANTA CHIANPIAN, M.D. on private complainant. 3. Exhibit “C” – Affidavit of Dr. CRISANTA CHIANPIAN, M.D.4. Exhibit “D” – Sinumpaang Salaysay of Barangay Tanod

Robinson Antonio.5. Exhibit “E” – Sinumpaang Salaysay of witness CECILIA

PINEDA6. Exhibit “F” – Affidavit of witness ANNA FESTIN7. Exhibit “G” – Affidavit of the victom’s mother PRINCESS

SUCOR8. Exhibit “H” – Criminal Investigation Report 9. Exhibit “I” – Birth Certificate of minor ABDUL RAFI ONOS.

WITNESSESWe respectfully intend to present the following witnesses:

1. Private Complainant – to prove the material allegation in the complaint.

2. Dr. CRISANTA CHIANPIAN, M.D. – Medico Legal Officer, to testify as to the examination conducted on private complainant and to attest to the veracity of the medical report prepared.

3. Barangay Tanod ROBINSON ANTONIO – Barangay Tanod who arrested the accused, together with the victim assisted by his mother.

4. CECILIA PINEDA – witness, to corroborate the testimony of the private complainant

5. ANNA FESTIN – Witness, to corroborate the testimony of the private complainant

6. PRINCESS SUCOR – witness, the victim’s mother

ISSUES The issue to be resolved by the Honorable Court is whether or

not the accused is guilty of the crime charged

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TRIAL DATES

We respectfully request for at least 3 trial days, with the regular appearance of the undersigned Assistant City Prosecutor before this Honorable Court.

Respectfully Submitted.

Pasay City, Philippines.

PASAY CITY PROSECUTORS OFFICEPasay City

By:

MA. ANNA CECILIA PINEDAAssistant City ProsecutorPTR No. 2133063; Pasay; 02-08-2010Roll of Attorneys No. 995423IBP No. 34560987; Pasay; 02-08-2010MCLE ExemptPTR Exempt

Copy Furnished:

ATTY. FRANCIS TANCounsel for the DefenseAddress: No. 18 Gagalangin Street Tondo Manila

Received By:Date:

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