Pre Trial Brief

Republic of the Philippines
REGIONAL TRIAL COURT

Second Judicial Region
BRANCH 01
Tuguegarao City, Cagayan
PEOPLE OF THE PHILIPPINES
-versus- CRIM CASE NO.

18626
CLINT BONDAD y MALIBUG, FOR:
Accused. RAPE
x ----------------------------------------x
PRE-TRIAL BRIEF
COMES NOW the plaintiff, PEOPLE OF THE

PHILIPPINES, by and through the undersigned prosecutor
and unto this Honorable Court most respectfully submits
this Pre-Trial Brief, as follows:
I.PROPOSED ADMISSIONS AND STIPULATION OF

FACTS
1. That accused CLINT M. BONDAD is the same person

named in the Information and that he was duly
arraigned before the Honorable Court on March 13,
2019;
2. That prior to the time material to the allegations in the

Information, private complainant CATRIONA GRAY y
INOSENTE and the accused attended a despedida
party at Pulsar Hotel, Enrile Avenue, Tuguegarao City
Cagayan;
3. That accused CLINT BONDAD y MALIBUG is residing

at 01 Taal Street, Cataggaman Pardo, Tuguegarao City,
Cagayan;
1
4. That the private complainant was examined by Dr.
____________________, On January 1, 2019 at Cagayan
Valley Medical Center, Tuguegarao City, Cagayan.
5. That the urine sample of the private complainant was

tested for urinalysis to determine the presence of
Spermatozoa by Medical Technologist Hazel Joy
Saludares of the Philippine National Police Regional
Crime Laboratory Office, Camp Marcelo Adduru,
Tuguegarao City, Cagayan.
6. That the urine sample of the private complainant was

tested for Drug Testing to determine the presence of
3,4-Methylenedioxy-Methamphetamine (MDMA) by
Medical Technologist Hazel Joy Saludares of the
Philippine National Police Regional Crime Laboratory
Office, Camp Marcelo Adduru, Tuguegarao City,
Cagayan.
II. FACTUAL/LEGAL ISSUES
1. Whether or not accused CLINT BONDAD y

MALIBUG committed the factual allegations in the
Information; and
2. If yes, whether or not accused CLINT BONDAD y

MALIBUG violated the provisions of Article 266-A(1)
(a)(b) of the Revised Penal Code as amended by RA
8353.
III. WITNESSES TO BE PRESENTED
1. CATRIONA GRAY y INOSENTE of Alley B, Caritan

Highway, Tuguegarao City, Cagayan – to testify the
details of the facts alleged in the Information;
2. PIA HANDRA ALONZO of Carig Norte, Tuguegarao

City, Cagayan- to testify on the facts immediately prior
to the incident alleged in the Information;
3. DANIELLE MAXINE GARCIA of San Gabriel,

Tuguegarao City, Cagayan – to corroborate the
testimony of PIA HANDRA ALONZO on the facts
immediately prior to the incident alleged in the
Information;
2
4. P03 ELAINE GALURA of Tuguegarao City Police
Station, Tuguegarao City, Cagayan – to testify
regarding the incident reported by private complainant
CATRIONA GRAY y INOSENTE on January 1, 2019.
5. DR. ______________________of Cagayan Valley Medical

Center - to testify on the medical examination she
conducted on the private complainant on January 1,
2019 and the content of the medico-legal report she
issued in connection with the said examination;
6. Medical Technologist Hazel Joy Saludares of Philippine

National Police Regional Crime Laboratory Office,
Camp Marcelo Adduru, Tuguegarao City, Cagayan. - to
testify on the urinary testings he/she conducted on the
urine samples of the private complainant and the
certificates she issued in connection with the said
laboratory examination.
Plaintiff reserves the right to present other witnesses and

documents if the need for it arises during the trial.
IV. APPLICABLE LAWS
1. Revised Penal Code;
2. Republic Act No. 8353, otherwise known as the “The

Anti-Rape Law of 1997”;
3. Revised Rules of Evidence; and
4. The Civil Code’s Provisions on Damages
V. PROPOSED EXHIBITS TO BE MARKED
1. Exhibits “A” and “A-1” – the Complaint Affidavit of

private complainant CATRIONA GRAY y INOSENTE
subscribed by Associate City Prosecutor Tim Mckey on
January 3, 2019 at the City Prosecution Office,
Tuguegarao City, Cagayan;
2. Exhibits “B” and “B-1”– the Joint-Affidavit of PIA

HANDRA ALONZO and DANIELLE MAXINE GARCIA
subscribed by Associate City Prosecutor Tim Mckey on
January 3, 2019 at the City Prosecution Office,
3
3. Exhibit “C” – Excerpt from Police Blotter under entry
no. 1089, page 199, volume number CLXII-D, series of
2019;
4. Exhibit “D” – Medico Legal Report Number BRO-MG-

10-35, dated January 1, 2019, issued by
Dr._____________________of Cagayan Valley Medical
Center, Tuguegarao City, Cagayan;
5. Exhibit “E” – Urinalysis Report dated January 1,

2019, issued by Medical Technologist Hazel Joy
Saludares of the Philippine National Police Regional
Crime Laboratory Office, Camp Marcelo Adduru,
6. Exhibit “F” – Drug Test Report dated January 1, 2019,

issued by Medical Technologist Hazel Joy Saludares of
Philippine National Police Regional Crime Laboratory
Office, Camp Marcelo Adduru, Tuguegarao City,
Cagayan.
Plaintiff respectfully reserves the right to submark the

foregoing exhibits and to mark other documentary exhibits
during the course of the trial, if the circumstances will
warrant.
V. TRIAL DATES
Plaintiff respectfully requests for eight (8) calendar

dates preferably two (2) days in a month, proposed as: April
16 and 18, 2019; May 13 and 15, 2019; June 4 and 6, 2019;
and July 15 and 17, 2019.
Most respectfully submitted.
April 11, 2019, Tuguegarao City, Cagayan.
TIM MCKEY
Associate City Prosecutor
MCLE Compliance No. VI-
01010101
4
Copy Furnished:
ATTY. JOHN F. MALANA

Counsel for the Accused
Public Attorney’s Office
Tuguegarao City, Cagayan

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Republic of the Philippines

REGIONAL TRIAL COURT

PEOPLE OF THE PHILIPPINES

-versus- CRIM CASE NO.

CLINT BONDAD y MALIBUG, FOR:

COMES NOW the plaintiff, PEOPLE OF THE

I.PROPOSED ADMISSIONS AND STIPULATION OF

1. That accused CLINT M. BONDAD is the same person

2. That prior to the time material to the allegations in the

3. That accused CLINT BONDAD y MALIBUG is residing

5. That the urine sample of the private complainant was

6. That the urine sample of the private complainant was

II. FACTUAL/LEGAL ISSUES

1. Whether or not accused CLINT BONDAD y

2. If yes, whether or not accused CLINT BONDAD y

III. WITNESSES TO BE PRESENTED

1. CATRIONA GRAY y INOSENTE of Alley B, Caritan

2. PIA HANDRA ALONZO of Carig Norte, Tuguegarao

3. DANIELLE MAXINE GARCIA of San Gabriel,

5. DR. ______________________of Cagayan Valley Medical

6. Medical Technologist Hazel Joy Saludares of Philippine

Plaintiff reserves the right to present other witnesses and

1. Revised Penal Code;

2. Republic Act No. 8353, otherwise known as the “The

3. Revised Rules of Evidence; and

4. The Civil Code’s Provisions on Damages

V. PROPOSED EXHIBITS TO BE MARKED

1. Exhibits “A” and “A-1” – the Complaint Affidavit of

2. Exhibits “B” and “B-1”– the Joint-Affidavit of PIA

4. Exhibit “D” – Medico Legal Report Number BRO-MG-

5. Exhibit “E” – Urinalysis Report dated January 1,

6. Exhibit “F” – Drug Test Report dated January 1, 2019,

Plaintiff respectfully reserves the right to submark the

Plaintiff respectfully requests for eight (8) calendar

Most respectfully submitted.

April 11, 2019, Tuguegarao City, Cagayan.

ATTY. JOHN F. MALANA

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