Republic of the Philippines

Department of Justice
TACLOBAN CITY PROSECUTION OFFICE
Bulwagan ng Katarungan
Magsaysay Boulevard, Tacloban City
People of the Philippines, Criminal Case No.0123456
Plaintiff,

-versus- For:

Rabiya Matthews QUALIFIED THEFT

Accused.
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PRE-TRIAL BRIEF

ACCUSED, RABIYA MATTHEWS, 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. Accused being charged with Qualified theft under Article 310 of the
Revised Penal Code for allegedly stealing the amount of Twenty
Thousand Pesos (P20,000) from the vault of KUDZ Fried Chicken Haus
Tacloban Branch at around 1:30 in the afternoon, on May 25, 2021.
2. Accused is the Branch Supervisor of KUDZ Friend Chicken Haus for 5 long
years.
3. Accused vehemently denies the malicious imputation against him, as the
truth of the matter is that accused did not work on the afternoon shift
on the said date, for it was her mother’s 60 th birthday celebration, and
just before she left for the morning shift, She asked permission from the
Head Supervisor, Catriona Wurtzbach, to have Pia Gray, the trainee to
take over the store operations. Around 6:00pm in the evening on the
same day, Accused received a call from PIA GRAY, requesting assistance
in the accounting of the day’s proceeds in the cash vault, and went
home immediately before closing time around 9:00pm.
 EVIDENCE FOR MARKINGS

1. Affidavit of accused, RABIYA MATTHEWS dated May 11, 2021.

2. Police Blotter of the incident on the event occurred on May 24,2021 at
8o’clock in the evening certified by PCpl Arafat Abah dated May 25,2021
at 4o’clock in the afternoon.
3. Affidavit of Witness dated May 26,2021 executed by Pia Gray.
4. Affidavit of Witness dated May 26,2021 executed by Pio Milby.

ISSUES

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

2. Whether or not they were guilty thereof.

WITNESS

1. Witness PIA GRAY, Supervisor-Trainee of KUDZ Fried Chicken Haus, to

testify on her execution of the affidavit of Witness dated May 26,2021.
2. Witness PIO MILBY, Security Guard of KUDZ Fried Chicken, to testify on his
execution of the affidavit of Witness dated May 26,2021.
3. Accused RABIYA MATHEW, Branch Supervisor of KUDZ Fried Chicken Haus
Tacloban Branch to testify on the matters and circumstances attending on
the missing proceeds of store, establishing her innocence of the offense
charged against her.
Accused reserves the right to present additional documentary and
testimonial evidence in the course of the trial, if necessary.

TRIAL DATES

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

RESPECTFULLY SUBMITTED.

Tacloban City, June 19,2021