REPUBLIC OF THE PHILIPPINES

FIRST JUDICIAL REGION

MUNICIPAL TRIAL COURT IN CITIES
NAGA CITY
BRANCH 001

Mr.GLENN RODEQUERIO
plaintiff

-versus- FOR: Slight Physical Injuries

Article 266 of the
Revised Penal Code

Mr.CICL XXX
defendant
x-----------------------------------------------x

PRE-TRIAL BRIEF OF THE DEFENSE

DEFENDANT, by counsel and through this Honorable

Court, respectfully submits this pre-trial court’s order dated,
January 15, 2010.

I. SUMMARY OF ADMITTED FACTS, PROPOSED

STIPULATION OF FACTS AND DEFENSES

The defendant hereby denies the following facts:

I.1. The Allegations against him;

I.2. The time and place of the commission of the offense;

Furthermore, the defendant respectfully proposes the

following facts:

I.3. At around 2:00 in the morning on January 1, 2010,

he and his family were having a celebration for the
New Year in their residence in WWW, Quezon City;
I.4. They heard a commotion outside and they were told
that there was a mauling incident that was
happening;
 I.5. His mother YYY went out first and then he, his
siblings and their visitors followed to the corner of
Cotabato Street. CICL XXX saw Redoquerio and De
los Santos mauling Narag;
I.6. Thereafter, De los Santos ran away while Narag
boxed Redoquerio who fell on his back. He did not
know what happened next because YYY already
called for him and they went home

The defendant, moreover, raises the following defenses:

I.7. He surmised that the reason why he was implicated

in this case is that Redoquerio did not really know
who mauled him;

II. ISSUE

II.1. Whether or not the defendant is justified in

committing the crime charged.

III. WITNESSES

III.1. YYY on the contents of her sworn affidavit and on

the contents of her sworn affidavit and strengthening
the defendant’s claim that he is not part of the
alleged mauling/attack
III.2. CICL XXX Siblings and cousin sworn affidavit and
on the contents of her sworn affidavit and
strengthening the defendant’s claim that he is not
part of the alleged mauling/attack

IV. TRIAL DATES

Specifically, all Fridays of the month, with the regular

appearance of the undersigned counsel before this
Honorable Court.

RESPECTFULLY SUBMITTED.
 Naga City, Philippines, January 15, 2010.

Copy furnished:

CHUCK NORRIS
Assistant City Prosecutor
Office of the City Prosecutor of Naga
Naga City

Received by: ___________

Date: ___________