Republic of the Philippines

REGIONAL TRIAL COURT

National Capital Judicial Region
Pasay City, Branch 98
THE PEOPLE OF THE
PHILIPPINES
Complainant,
Criminal Case No. 38, 390-15
FOR: Violation of Section 10 (a),
Article VI of Republic Act No. 7610
-versus-

RONALD VERDUGO
Accused.
x--------------------------------x

PRE-TRIAL BRIEF
ACCUSED, through the undersigned counsel, before
Honorable Court, most respectfully submit this Pre-Trial Brief.

this

A. ADMISSION AND STIPULATION OF FACTS

Other than those alleged in the Counter-Affidavit, none at the
moment.
B. EVIDENCE FOR MARKINGS
1. Counter Affidavit of Accused to prove the truthfulness of his
denials to the case as EXHIBIT A.
2. Grades of Anna Cruz at her former school as EXHIBIT B.
3. Publicly displayed photos of Anna Cruz with her friends
drinking alcohol and smoking cigarettes, public display of
affection with a guy as EXHIBIT C.
4. Photos of the cigarettes and foils used for illegal drugs as
EXHIBIT D.
C. ISSUES
1. Whether or not the Accused is committed the offense
charged;
2. Whether or not the Accused was guilty thereof.

D. WITNESSES
1. Accused Ronald Trinidad to testify on the matters and
circumstances attending to the case.
2. Anna Delo Santos and Christian Del Flores to prove that the
accused did not physically and verbally abused the child.
3. Natalie Estacia and Leidi Bayadun to prove that the child has
vices and stays outside until dawn.
E. TRIAL DATES
Specifically all Fridays of the month, with regular appearance of
the undersigned counsels before this Honorable Court.
RESPECTFULLY SUBMITTED.
City of Manila for Quezon City. 13 February 2015.
Assisted by counsel:

JASREEL DOMASING
ROLL OF ATTORNEYS NO. 12345
IBP Lifetime No. 08888/Manila III
PTR NO. 77777/Jan. 7, 2015/MLA
MCLE Compliance: IV-0002279/20 January 2012

Copy Furnished and Explanation

LEIDA MAE BUMANLAG
#22 Maria Clara St., Zigzag Road
Mapayapa, Pasay City
The filing and/or service of the foregoing is/are via registered mail or
alternative courier due to absence of manpower to effect personal filing and/or
service and/or due to the distance involved and time constraints. (Please
disregard if the filling and/or service was/were effected personally.)

JASREEL A. DOMASING