Republic of the Philippines

Regional Trial Court

13th Judicial Region
Branch 15
Dumaguete City

THE PEOPLE OF THE Criminal Case No. 38,390

PHILIPPINES FOR: RAPE

Complainant,

-versus-

Valz Demreeve P. Salma

Accused,

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

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 Escaño 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. Salma—Exhibit “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 Bocelli—Exhibit “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
incident—Exhibit “H” produced in print which contains the
conversation between the offended party and the accused, and
offended party’s suggestion of marriage after the incident.

D. NAME OF WITNESSES

1. Accused Valz Demreeve P.Salma—he will testify on his own

behalf to prove his innocence;

2. Andrea Bocelli—she 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: ___________