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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT


6th Judicial Region
Branch 51
Bacolod City, Negros Occidental

CORAZON FERNANDEZ-SOLIS,
Plaintiff,

-versus- Civil Case No. ______


For: PETITION FOR
CUSTODY OF MINOR
CHILDREN

PURITA CAKTIONG,
Defendant.

x---------------------------------x

PRE-TRIAL BRIEF OF THE PROSECUTION

COMES NOW, the undersigned counsel for the Petitioner, and


unto this Honorable Court, respectfully submits this Pre-Trial Brief,
as follows:

PROPOSED FACTS FOR ADMISSION

1. Jurisdiction of the Honorable Court and the identity of the


accused.
2. Identity of the Parties.
3. That the childrens parents and sister were killed inside their
family home.
4. That a complaint-affidavit was filed accusing the brothers
of the children, Daryl and Marvin of parricide and double
murder for the death of their parents and sister.
5. That the petitioner immediately went back to Iloilo City to
bring the six minor Caktiong children to safety in Bacolod
City upon knowledge of the complaint filed against the
accused brothers.
6. That the defendant refused to turnover the custody of the
children
7. That the petitioner made several requests to the defendant
to turn over the custody of the minor children.
8. That the defendant deliberately refused to turn over the
custody of CHILDREN to the petitioner.

9. That the Caktiong children remains in the custody of Purita


Caktiong and are not allowed to see any visitors.

DOCUMENTS TO BE PRESENTED

ANNEXES:

A- Certificate of Live Birth of Clarisse Caktiong

B- Certificate of Live Birth of Kyle Caktiong

C- Certificate of Live Birth of Danielle Caktiong

D- Certificate of Live Birth of Maureen Caktiong

E- Certificate of Live Birth of Claire Caktiong

F- Certificate of Live Birth of Faith Caktiong

G- Police Report
H- Decision of the RTC with regard to the appointment of Purita
Caktiong as the administratrix of the estate of Charlie and
Clarisse Caktiong

LIST OF WITNESSES

1. Corazon Fernandez- Solis- She is the petitioner in the


present case. She will narrate the events that occurred
from the day that she requested Purita Caktiong to
turnover the custody of the five minor children.

2. Ramona Real- She accompanied the petitioner during its


attempt to gain custody of the five minor children. She will
testify that the defendant refused to turnover the custody
of the children and even declined to let the petitioner see
the children.

3. Ismael Recto- He is a bananacue vendor at M.H. del Pilar


St., Molo, Iloilo City at the front of the Caktiong compound.
He will testify that the defendant refused to let the plaintiff
visit the five minor children.

4. Dr. Natalia Bautista- She is the physician who conducted a


full physical examination on the petitioner, Corazon
Fernandez- Solis. She will testify that the petitioner is healthy
and will be able to provide appropriate care to the five
minor Caktiong children.

TRIAL DATES

The undersigned needs at least three (3) trial dates.

ISSUES TO BE RESOLVED

Whether or not the plaintiff should be awarded custody of


the five minor Caktiong children.
RESPECTFULLY SUBMITTED.

Bacolod City, Philippines, January 7, 2017.

ATTY. ROBERT NAVAREZ


COUNSEL FOR THE PETITIONER
Roll of Attorneys N0. 4567
MCLE Compliance No. III-0013461
PTR No. 5709132; 1/5/17
IBP N0. 675201
Bacolod City

ATTY. ANNIE ROSE ROSALES


COUNSEL FOR THE PETITIONER
Roll of Attorneys N0. 4789
MCLE Compliance No. III-0010987
PTR No. 456739; 1/5/17
IBP N0. 87878
Bacolod City

Copy Furnished:

OFFICE OF THE CITY PROSECUTOR


Bacolod City
3rd floor Hall of Justice
Bacolod City, Negros Occidental