TRIAL COURT

BRANCH 2
Tagbilaran Republic of the Philippines
7th Judicial Region
REGIONAL City, Bohol

THE PEOPLE OF THE PHILIPPINES

Plaintiff, Criminal Case No. 25826 & 25827
-versus-
For:
VIRGILIO CABIDO SR.. SECS. 5, & 11 of , R.A. 9165
Accused.
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PRE-TRIAL BRIEF FOR THE ACCUSED

ACCUSED through herein undersigned counsel, in the above-entitled case, and to the
Honorable Court, most respectfully submits his Pre-Trial Brief, and state:

I. BRIEF STATEMENT OF THE ACCUSED

Accused vehemently denies all allegations against him in the Informations

charged against him for violations of Secs. 5& 11 of R.A. 9165;

That his defense is denial. He was just framed up by the police and forced to
participate in a mock inventory and buy-bust operation where he was portrayed as
the subject.

II. POSSIBILITY OF AMICABLE SETTLEMENT

none.

III. STIPULATION/ADMISSION OF FACTS

None.

IV. PROPOSED STIPULATION OF FACTS

 None

V. THE ISSUES TO BE TRIED OR RESOLVED

 Whether or not Accused is guilty beyond reasonable doubt of the crimes above-
mentioned.

VI. NUMBER AND NAMES OF WITNESS TO BE PRESENTED

1. Accused Virgilio Cabido Sr.

-To refute all the allegations in the complaint.

 Accused reserve to name other witnesses if necessary;

VII. DOCUMENTS OR EXHIBITS TO BE PRESENTED

Accused reserves the right to present additional documentary or object evidence

during the trial, if necessary.

VIII. APPLICABLE LAWS AND JURISPRUDENCE

1. Revised Penal Code

2. Applicable jurisprudence established by the Supreme Court
3. R.A. 9165

IX. AVAILABLE TRIAL DATES

Herein Accused will abide by the calendar of the Honorable Court.

Respectfully submitted.

City of Tagbilaran, this March 3, 2023.

PUBLIC ATTORNEY’S OFFICE

Tagbilaran City District Office
Hall of Justice, New Capitol Site
Tagbilaran City

By:

MICHAEL JORDAN M. TUBAL

Public Attorney I
Roll No. 75791
IBP O.R. No. 190705 PTR No. 4674085-Bohol-01/04/2023
MCLE Compliance No. VII- 0010126- 02/15/2022

Personal Delivery
PROVINCIAL PROSECUTION OFFICE
Pros. Dexter A. Bernales