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Republic of the Philippines

Regional Trial Court


13
th
Judicial Region
Branch 15
Dumaguete City



THE PEOPLE OF THE
PHILIPPINES

Complainant,

-versus-


Valz Demreeve P. Salma

Accused,

x---------------------------------------------x
Criminal Case No. 38,390
FOR: RAPE


PRE-TRIAL BRIEF OF THE ACCUSED

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

A. SUMMARY OF ADMITTED FACTS, AND PROPOSED
STIPULATION OF FACTS

The accused admits the following:

1. That the Honorable Court has jurisdiction over the case;

2. That the identity of the one charged in the information and that
of the person arraigned is one and the same;

3. That I am the defendant in the case;

4. The identity of the offended party, Yasmeen Junaid;

5. That Yasmeen Junaid is my girlfriend;

6. That Yasmeen Junaid consented to the intimate acts that
happened during the incident;

7. That Yasmeen Junaid suggested that I marry her via text
message, after the incident;

8. That the incident took place on March 17, 2014 at around 6:30
in the evening at Escao beach, Dumaguete City.

B. ISSUE TO BE TRIED

Whether or not the accused is guilty of the crime charged.


C. EVIDENCE FOR MARKINGS

1. Affidavit of accused, Valz Demreeve P. SalmaExhibit F a
sworn written statement to prove that the acts of the accused did
not constitute the crime of rape;

2. Affidavit of witness, Andrea BocelliExhibit G a sworn written
statement to prove the relationship between the offended party
and the defendant;

3. Electronic evidence of several text messages exchanged between
the offended party and the defendant before and after the
incidentExhibit H produced in print which contains the
conversation between the offended party and the accused, and
offended partys suggestion of marriage after the incident.

D. NAME OF WITNESSES

1. Accused Valz Demreeve P.Salmahe will testify on his own
behalf to prove his innocence;

2. Andrea Bocellishe is a friend of the accused and the offended
party and he will testify on behalf of the accused.

E. TRIAL DATES

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

RESPECTFULLY SUBMITTED. April 20, 2014, Dumaguete City,
Philippines.

BENIGAY LAW OFFICE
San Pedro Extension, Dumaguete City

By:

Atty. Precious Edlyn Benigay
Defense Counsel
Roll No. 68999 / 5-2-07
IBP. No. 789084 / 12-29-07
MCLE Compliance No. 890590 / 12-20-07
PTR No. 345667 / 01-05-08


Copy furnished:
PROS. FRANCIS GEORGE S. YAP
City Prosecutor
Dumaguete City Prosecution Office
Hall of Justice
Piapi, Dumaguete City

PROS. ROSEL Q. ERAMES
Asst. City Prosecutor
Dumaguete City Prosecution Office


Received by:___________
Date: ___________