Republic of the Philippines

7th Judicial Region

REGIONAL TRIAL COURT
BRANCH 2
Tagbilaran City, Bohol

THE PEOPLE OF THE PHILIPPINES

Plaintiff, Criminal Case No. 25345
-versus-
For:
MARLOU PODADOR Y OMANA Frustrated Murder
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 the allegations in the information that without lawful
authority and with criminal intent to unlawfully, feloniously, freely and knowingly shoot
one Archie L. Podador in the lateral right chest, abdomen, right arm;

That his defense is denial. He was asleep in hisat the time of the alleged incident. He
does not go out much during night time since his house is far from the highway.

II. POSSIBILITY OF AMICABLE SETTLEMENT

The accused is very open to the possibility of an amicable settlement.

III. STIPULATION/ADMISSION OF FACTS

None.

IV. PROPOSED STIPULATION OF FACTS

 None of the witnesses actually saw the accused in shooting the victim;

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 Marlou O. Podador

-To refute all the allegations in the complaint.

2. Marcelo Podador

- to prove that the accsued was indeed asleep in his home

3. Ligel Fuentes
 -to corroborate the testimony of the accused

Defendants reserve to name other witnesses if necessary;

VII. DOCUMENTS OR EXHIBITS TO BE PRESENTED

Defendant reserves the right to present additional documentary or object evidence in the
course of the trial, if necessary.

VIII. APPLICABLE LAWS AND JURISPRUDENCE

1. Revised Penal Code

2. Applicable jurisprudence established by the Supreme Court

IX. AVAILABLE TRIAL DATES

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

Respectfully submitted.

City of Tagbilaran, this September 15, 2022.

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. 2467440-Bohol-01/11/2022
MCLE Compliance No. VII- 0010126- 02/15/2022

Personal Delivery
PROVINCIAL PROSECUTION OFFICE
Pros. DEXTER A. BERNALES