Republic of the Philippines

Second Judicial Region

REGIONAL TRIAL COURT
BRANCH 16
City of Ilagan, Isabela

THE PEOPLE OF THE PHILIPPINES,

Plaintiff,
CRIMINAL CASE NO.
-versus-
For: TRAFFICKING
IN PERSON
=
Accused.
x- - - - - - - - - - - - - - - - - - - - - - - -x

PRE-TRIAL BRIEF
(For the Defense)

Accused, by the undersigned counsel, unto this Honorable Court,

most respectfully submits this Pre-Trial Brief:

PLEA-BARGAINING

The accused does not want to enter into a Plea-bargaining with the
prosecution.

PROPOSED STIPULATIONS OF FACTS BY THE DEFENSE

The defense admits the identity of the accused as the very same
person named and charged under the information and duly arraigned on
December 11, 2020.

NO PROPOSED STIPULATIONS OF FACTS BY THE DEFENSE

ISSUES

Factual Issue:

(The accused joins the factual issue raised by the prosecution)

Legal Issue: Whether or not accused is liable for Trafficking in Person,

defined under Section 4 (a), in relation to Section 3(a), and penalized under
Section 10 (a), of Republic Act No. 9208, as amended by Republic Act No.
10364.

EVIDENCE
Documentary evidence: The accused reserves the marking of any
documentary exhibits during the course of the trial.

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 WITNESSES

1. The accused herself Cora Taguimacom y Legazpi

RESERVATION

The defense reserves the right to present additional witnesses in the

course of the trial.

DEFENSE OF THE ACCUSED

The defense of the accused is denial.

APPLICABLE LAWS AND JURISPRUDENCE

The defense invokes all applicable laws primarily Republic Act No.
9208, Republic Act 10364, the 2000 Revised Rules on Criminal procedure,
the 2019 Amended Rules on Evidence and other related laws, rules,
doctrines and jurisprudence of the Supreme Court.

Accused respectfully prays for three (2) trial dates after the
prosecution has rested its case.

Respectfully submitted.

City of Ilagan, Isabela on 07 July 2022.

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