Republic of the Philippines

REGIONAL TRIAL COURT

Branch 67
Makati City

PEOPLE OF THE PHILIPPINES, CRIMINAL CASE NO. 3345-12

Plaintiff, FOR: MURDER

- versus -

ANALYSE FLORENDO,
Accused.
x-----------------------------------------------x

PRE-TRIAL BRIEF OF THE ACCUSED

ACCUSED, through the undersigned counsel, before this Honorable Court,

most respectfully submit this Pre-Trial Brief:

SUMMARY OF ADMITTED FACTS

AND PROPOSED STIPULATION OF FACTS

The accused admit the following:

1. the identities of those charged in the information and that of the
persons arraigned are one and the same;
2. the identity of Lily Marie Pementel, the victim;
3. the killing of the victim;
4. the date, place and time of the killing, which was March 5, 2018 at
about 2:30 in the morning and at Corner Quirino Sts., Makati City.

EVIDENCE FOR MARKINGS

1. Affidavit of accused, ANALYSE FLORENDO

Purpose: to prove that he admits the killing of the victim but the same was done
in self-defense;
2. Medical Report issued by Dra. Shin F. Mandaro, to ANALYSE FLORENDO
Purpose: to prove that the accused sustained several wounds as a result of the
aggression by the victim;
3. Blotter Report of Makati Police Station (ICP-PP4)
Purpose: to prove that the accused ANALYSE FLORENDO voluntarily surrendered
to the Police authorities.
 ISSUES

1. Whether or not the accused committed the crime charged;

2. Whether or not they were guilty thereof.

WITNESSES

1. Accused ANALYSE FLORENDO to testify on the matters and

circumstances attending the killing of the victim;
2. Witness Jun-Jun Parinas to testify on the exchange of words and blows
between the accused ANALYSE FLORENDO and the deceased which resulted to
the death of the victim;
3. Dra. Shin F. Mandaro to testify on the veracity of the findings stated in
the medical report of Gabriel Salas.

TRIAL DATES

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

RESPECTFULLY SUBMITTED.

Makati, Philippines, May 7, 2019

AIRHA KAE V. PORNELDA

Counsel for the Defense
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. SHEEN F. ALLIGA

Assistant City Prosecutor
Bonifacio Drive, Makati City

Received by:___________
Date: ___________