Republic of the Philippines

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
Pasay City, Branch 53

PEOPLE OF THE PHILIPPINES,

Plaintiff,

- Versus - CRIM. CASE NO. 5409

For: Kidnapping for Ransom

BRYAN ZAFRA
AIKEN LOPEZ
RYAN CAF
ALBERTO MANALANG
Accused.

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PRE-TRIAL BRIEF
OF THE ACCUSED

THE ACCUSED, by counsel, respectfully submits the following Pre-trial Brief:

SUMMARY OF ADMITTED FACTS

The following are the admitted facts:

1. The incident was reported to the police on November 6, 2012;

2. The accused were arrested on February 15, 2013;

 DOCUMENTARY EXHIBITS

EXHIBITS DESCRIPTION
1

The accused reserves the right to present additional documentary evidence during the pre-
trial.

TESTIMONIAL EVIDENCE
The accused intends to present the following witnesses:

(a) The accused persons shall testify on the material averments contained in their
counter-affidavit;

(b) Julian Roman Reyes shall testify on his affidavit and the truth of the matters
contained therein;

(c) Erwin B. Belen shall testify on his affidavit and the truth of the matters
contained therein;

(d) Rupert Aaron Villarico shall testify on his affidavit and the truth of the matters
contained therein;

(e) Ma. Brimar Makasiar shall testify on his affidavit and the truth of the matters
contained therein;

The accused reserves the right to present additional documentary evidence during the pre-
trial and trial.
 ISSUES TO BE TRIED
The accused submits the following issues for the resolution of this Honorable Court:

I. Whether the accused persons were actually and physically present at the time and
place when the crime of kidnapping for ransom was committed as to warrant
conviction of the same;

II. Whether the accused is guilty in accordance of the quantum of evidence required and
the elements of the crime of kidnapping for ransom.

TRIAL DATES
We respectfully request for at least 3 trial days, with the regular appearance of the
undersigned City Prosecutor before this Honorable Court.

Respectfully submitted.

Makati City for Pasay City, Philippines, August 17, 2013.

SILVERIO LAW OFFICES

Counsel for the Accused

5th Floor, Makati Executive Tower III

167, Gil Puyat Avenue, Makati City

BY:
ATTY. MELVIE E. SILVERIO
Roll of Attorney No. 51486

PTR No. 0987256, Jan. 4, 2009, Pasay

Series No. of Commission 0854481

IBP No. 729988