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REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION


REGIONAL TRIAL COURT
BRANCH 65
CITY OF MAKATI

PEOPLE OF THE PHILIPPINES,


Plaintiff,

RTC CRIM. CASE NO. 165378


- versus - For: Human Trafficking in
violation of Sec. 4 of R.A.
10364
RAYMOND DEL ROSARIO Y
LAUDENCIA
Accused.
x------------------------------------------x

PRE-TRIAL BRIEF
(FOR THE PLAINTIFF)

PEOPLE OF THE PHILIPPINES, through the undersigned


Prosecutors, most respectfully submits this Pre-Trial Brief and states the
following:

A. SUMMARY OF ADMITTED FACTS AND PROPOSED


STIPULATION OF FACTS

1. That the private complainant, CLIO G. ROXAS, hereinafter referred


to as complainant, is 20 years of age, born on April 16, 1997, single,
Filipino, and resident of 107 Kalayaan Ave., Brgy. Poblacion, Makati
City.

2. That private complainant was with ANNA L. SOBERANO, a new


recruit, who was 17 years of age, Filipino, resident of 22 Polaris Street,
Brgy. Poblacion, Makati City at the time of the alleged incident.

3. That JENNY SOBERANO is the mother of the Anna Soberano, 37


years of age, Filipino, and resident of 22 Polaris Street, Brgy.
Poblacion, Makati City.

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4. That the accused, RAYMOND DEL ROSARIO Y LAUDENCIA,
hereinafter referred to as accused, is 35 years of age, single, Filipino,
and a resident of 1993 Kamagong Street, Brgy. Palanan, Makati City

5. That the accused is personally known to the complainant.

6. That on ___ 2017, the accused invited complainant to participate in his


dating service in Makati. He promised that through this service, the
complainant will get the opportunity to meet rich men, usually
foreigners, who would be willing to buy the complainant whatever she
wanted.

7. The accused called the customers sugar daddies and he called the
complainant as the sugar baby.

8. That on ___, 2017, the complainant participated in the accuseds


foreign dating service and was assigned to Mr. Kam Jin Soo, to which
complainant verbally agreed. It was agreed upon that complainant will
do whatever Mr. Kam wants her to do while she was in his company
for three days, while he was in town. In exchange for complainants
services, Mr. Kam will give the latter a Balenciaga bag, particularly the
Classic Metallic Edge City Leather Tote.

9. That at around 8 oclock in the evening of __ 2017, the complainant


met Mr. Kam for the first time. He picked complainant up in Starbucks
at Century City mall, Kalayaan Ave., Makati, where they went to his
condominium unit 1003 in Century City and had carnal relations. This
setup went on for all the three days that the complainant was assigned
to him.

10.That on ___, 2017, I received a phone call from the accused advising
complainant that he can already make it up to her. He said that he had
new clients to his dating service. He promised that these sugar
daddies were very generous. After sufficient prodding, the
complainant agreed to participate in the dating service again.
Thereafter, the accused informed the complainant to meet the new
clients on ___, 2017 at the Manila Peninsula lobby.

11. That around 7:00 pm on ___, 2017, the complainant went to Manila
Peninsula lobby to meet the new sugar daddies. Complainant was with
Anna L. Soberano, a new recruit who was 17 years of age.

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12. That the clients arrived around 7:30 that same night. Anna and Ithe
complainant introduced themselves as their new sugar babies.

13.Instantly, they were surrounded by men who claimed to be NBI agents.

14. That around 8:00 oclock, the complainant and Anna were brought to
the Makati NBI station in Park Square 1, Theater Drive, Makti City.

B. ISSUES TO BE TRIED

WHETHER OR NOT THE ACCUSED COMMITTED THE CRIME OF


HUMAN TRAFFICKING

C. EVIDENCE

WITNESSES TO BE PRESENTED
1. Complainant Clio G. Roxas herself, who will testify on the
circumstances and acts committed by the accused which
constitutes human trafficking in violation of Sec. 4 of R.A. 10364.
2. Anna Soberano, who will testify concerning the acts committed
by the accused which constitutes human trafficking in violation
of Sec. 4 of R.A. 10364 and to establish that she was underaged
at the time of the commission of the trafficking.
3. Jenny L. Soberano, the mother of Anna Soberano, to establish
that Anna was indeed underaged at the time of the questioned
incident.
4. Agent Rogelio G. Cruz, the designated Undercover NBI Agent
to entrap the accused, who will testify on the what has transpired
during the night of the arrest of the accused.

DOCUMENTARY EVIDENCE and OBJECT EVIDENCE FOR


MARKING

1. Complaint-Affidavit of the complainant


2. Joint-Affidavit of arrest
3. PNP Booking form
4. Certificate of no record of birth
5. Photographs of the Hotel Lobby of Manila Peninsula
6. Screen shots of Text messages of Raymond Del Rosario

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D. AVAILMENT OF MODES OF DISCOVERY
The plaintiff respectfully reserves his right to avail of discovery
procedures as may be necessary.

E. DATES OF HEARING
The plaintiff is willing to attend the hearings on the dates agreed upon
during the pre-trial hearing.

Respectfully submitted.
RTC BRANCH 65, MAKATI
29 October, 2017

MAKATI CITY PROSECUTORS OFFICE


Makati City Hall, J.P. Rizal Street
Makati City

By:

Prosecutor Carlo Chungunco


City Prosecutor
Roll of Attorneys No.
IBP No.
Prosecutor Nester Mendoza
Assistant City Prosecutor
Roll of Attorneys No.
IBP No.

Prosecutor Mara Ruiz


Roll of Attorneys No.
IBP No.

Copy furnished through personal service:

Atty. Anton Mercado


Atty. Jose Norberto Sanchez
Atty. Codei Mariel Beatrice Buendia
Counsels for the accused
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Public Attorneys Office
Makati City Hall, J.P. Rizal Street
Makati City