Republic of the Philippines

REGIONAL TRIAL COURT OF BOHOL

7th Judicial Region
Branch III
Tagbilaran City

THE PEOPLE OF THE PHILIPPINES,

Plaintiff,

Criminal Case No. __________

For: Violation of Sec. 5 (e.2) & (i) of
R.A. NO. 9262
-versus –

ROBERT CALA y AUTIDA,

Accused.
x-------------------------------------/

PRE-TRIAL BRIEF OF THE PRIVATE COMPLAINANT

The undersigned Counsel for the plaintiff unto this Honorable Court
most respectfully submits its Pre-trial Brief as follows:

1. ISSUES TO BE RESOLVED.

Whether or not the accused is guilty of the crime charged

2. EVIDENCE TO BE PRESENTED.

Exhibit Document Purpose

“A” Complaint-Affidavit To prove among
executed by private others, that the
complainant Lucy R. accused has
Autida committed violation
of R.A. 9262
paragraph (i);
“B” Certificate of To prove among
Marriage by the others, that the
Private Complainant Complainant and the
and the Accused Accused are married;
“C” Bank Statement of the To prove among
Accused issued by others, that the
BPI Accused has been
sending money to the
mother of his child
from another woman
not his wife, and that
 he has enough money
to support his wife as
an obligation
thereafter when he
left;
“D” Certificate of To prove among
Employment from others, that the
Global Maritime accused has been
Performance and employed;
Solutions, Inc. dated
December 2020 to
March 2021
“E” Tickets of the ship on To prove among
October 10, 2020 and others, that the
bus ticket from Private-Complainant
Cagayan de Oro to went to the hometown
Calinan, Davoa City of the Accused only to
find out that the
Accused has been
living with his child
and the mother;

“F” Psychological Report To prove among

of my consultation to others,
Dr. Angelo Sierras, that my psychological
Psychiatrist and mental being has
been greatly affected;

“G” Bank Statement of the To prove among

Private Complainant others, that the
issued by BPI Accused has cut off
her allotee;
“H” Transfer of Certificate To prove among
Title of Rosario others, that the
property under the Accused has acquired
name of the Accused property under his
name;
“I” Transfer of Certificate To prove among
of Title of Rosario, others, that the
Cortes property under Accused has acquired
the name of the property under his
Accused name;
“J” Certification of To prove among
Registration of the car others, that the Private
Private complainant Complainant and the
and the Accused Accused has acquired
property under both
names;
 “K” Call history and text To prove among
messages history of others that, the Private
the Private Complainant has been
Complainant and the doing her efforts to
Accused win the Accused back,
that the replies of the
Accused causes
repeated verbal abuse
to the Private
Complainant and to
prove that the Private
Complainant
demanded for
financial support.
“L” Allotment History To prove among
issued by Global others, that the Private
Maritime Performance Complainant was the
and Solutions, Inc. Allotee of the
dated January 2020 to Accused up until
August 2020. August 2020.

Reserve to mark other documentary evidence or exhibits relevant or

material to the case will be presented and marked during the pre-trial
proper and/or trial as soon as they become available to the plaintiff
and/or their relevancy or materiality to the case shown.

3. RESORT TO DISCOVERY PROCEDURES. The plaintiff does not

intend to avail discovery procedures or referral to commissioners.

4. NAMES OF WITNESSES, ADDRESSES, SUBASTANCE OF

TESTIMONIES, APPROXIMATE DURATION OF TESTIMONIES.

1. LUCY R. She will testify and At least one hour.

AUTIDA substantiate the
allegations on the
Information.
2. DR. ANGELO He will testify on the At least 30 minutes.
B. SIERRAS truth of the
psychological report.
3. ANA E. TALA She will testify that At least 30 minutes.
she has been present
and has seen the
heated altercation of
the private
complainant and the
accused and had
accompany the
private complainant in
 going to Calinan
where they saw that
the accused has been
living with his child
and the mother of the
child.

RESPECTFULLY SUBMITTED.

Tagbilaran City Bohol, Philippines, April 8, 2021.

____________________
Associate Provincial Prosecutor
MCLE No. VI-0001122

____________________________
Provincial Prosecutor