Regional Trial Court: Summary of Admitted Facts and Proposed Stipulation of Facts

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Republic of the Philippines

Sixth Judicial Region


REGIONAL TRIAL COURT
Branch___
Iloilo City
PEOPLE OF THE PHILIPPINES,
Plaintiff,

CRIMINAL CASE NO._______


FOR: SEC 5 RA 9262

- versus CABANTUD RALPH NHEY,


Accused.
x-----------------------------------------------x
PRE-TRIAL BRIEF OF THE ACCUSED
ACCUSED, through the undersigned counsel, before this Honorable Court,
most respectfully submit this Pre-Trial Brief:
SUMMARY OF ADMITTED FACTS
AND PROPOSED STIPULATION OF FACTS
The accused admit the following:
1. the identities of those charged in the information and that of the
persons arraigned are one and the same;
2. the identity of Mae Lailour Cabantud, the victim;
3. the residence of spouses Cabantud

EVIDENCE FOR MARKINGS


1. Affidavit of accused, Ralph Nhey Cabantud
Purpose: to prove that he denies the allegation of Mae Lailour Cabantud under
the said Section 5(l) and Sec 5 (b) of RA 9262;
2. Affidavit of accused, Salvacion Sy Comoda, mother of the victim.
Purpose: to prove that her daughter, Mae Lailour is making up stories with
regard to his son in law having an abusive tendencies because he is having an
affair with another man.
3.

Affidavit of Rodolfo Angelo, Teacher of Mary Joy Cabantud ( accused

daughter)
Purpose: to prove that the allegation of Mae Lailour Cabantud about the accused
on forcing his child to be absent in school is false.

ISSUES
1. Whether or not the accused committed the crime charged;
2. Whether he is guilty thereof.
WITNESSES
1. Accused Ralph Nhey Cabantud to testify on the matters and
circumstances attending all the allegation of violation SEC 5 (B) and (l) of RA
9262;
2. Salvacion Sy Comoda to testify that Mae Lailour is fond of making
stories and telling lies about the whole incident because she is having an affair
with another man.
3. Witness Rodolfo Angelo to testify the falsity of Mae Lailour Comoda's
allegation on having their child forced not to go to school.

TRIAL DATES
Specifically all Saturdays of the month, with the regular appearance of the
undersigned counsels before this Honorable Court.
RESPECTFULLY SUBMITTED.
Iloilo City, Iloilo, Philippines, December 13 2014

By:
CHARMA ROSE BABAYO
Counsel for the Defense
Roll No. 68999 / 5-2-07
IBP. No. 789084 / 12-29-07
MCLE Compliance No. 890590 / 12-20-07
PTR No. 345667 / 01-05-08
And

MARC LOVEL BEDONA


Counsel for the Defense
Roll No. 69009 / 5-2-07
IBP. No. 789085 / 12-29-07
MCLE Compliance No. 890591 / 12-20-07
PTR no. 345668 / 01-05-08

Copy furnished:
Office of the Prosecutor
Ramon Q. Avancea Hall of Justice
Bonifacio Drive, Iloilo City

Received by:___________
Date: ___________

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