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REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION


REGIONAL TRIAL COURT
BRANCH 109, PASAY CITY
PEOPLE OF THE PHILIPPINES,
- versus

CRIM. CASE NO: 6572


For: RAPE

JAYSON RAMOS y SANTOS


1234 Sandejas St. Brgy 4, Pasay City
(Detained)
Accused.
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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 FACTS
AND 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:

1.
2.
3.
4.
5.
6.
7.
8.
9.

EVIDENCE FOR MARKINGS


Exhibit A Sinumpaang Salaysay of the Private Complainant.
Exhibit B Medico-legal certificate of examination conducted
by Dr. CRISANTA CHIANPIAN, M.D. on private complainant.
Exhibit C Affidavit of Dr. CRISANTA CHIANPIAN, M.D.
Exhibit D Sinumpaang Salaysay of Barangay Tanod
Robinson Antonio.
Exhibit E Sinumpaang Salaysay of witness CECILIA
PINEDA
Exhibit F Affidavit of witness ANNA FESTIN
Exhibit G Affidavit of the victoms mother PRINCESS
SUCOR
Exhibit H Criminal Investigation Report
Exhibit I Birth Certificate of minor ABDUL RAFI ONOS.

WITNESSES
We 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 victims mother

ISSUES
The issue to be resolved by the Honorable Court is whether or
not the accused is guilty of the crime charged

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 OFFICE
Pasay City
By:
MA. ANNA CECILIA PINEDA
Assistant City Prosecutor
PTR No. 2133063; Pasay; 02-08-2010
Roll of Attorneys No. 995423
IBP No. 34560987; Pasay; 02-08-2010
MCLE Exempt
PTR Exempt

Copy Furnished:
ATTY. FRANCIS TAN
Counsel for the Defense
Address: No. 18 Gagalangin Street Tondo Manila
Received By:
Date: