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    Pre Trial Brief

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    barrystarr1
    Valz Demreeve P. Salma is accused of raping Yasmeen Junaid on March 17, 2014 at Escaño beach in Dumaguete City. Salma's defense counsel submitted a Pre-Trial Brief to the court admitting some facts but arguing that Salma is not guilty of rape. The brief outlines 8 facts that Salma admits, identifies the sole issue to be tried as Salma's guilt, and lists 3 proposed exhibits and 2 witnesses that will testify on Salma's behalf in order to prove his innocence. The brief requests that trials be held on Fridays.

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    Pre Trial Brief

    Uploaded by

    barrystarr1
    90 views3 pages
    Valz Demreeve P. Salma is accused of raping Yasmeen Junaid on March 17, 2014 at Escaño beach in Dumaguete City. Salma's defense counsel submitted a Pre-Trial Brief to the court admitting some facts but arguing that Salma is not guilty of rape. The brief outlines 8 facts that Salma admits, identifies the sole issue to be tried as Salma's guilt, and lists 3 proposed exhibits and 2 witnesses that will testify on Salma's behalf in order to prove his innocence. The brief requests that trials be held on Fridays.

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    240649593-Pre-trial-Brief.docx

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    Valz Demreeve P. Salma is accused of raping Yasmeen Junaid on March 17, 2014 at Escaño beach in Dumaguete City. Salma's defense counsel submitted a Pre-Trial Brief to the court admitting some facts but arguing that Salma is not guilty of rape. The brief outlines 8 facts that Salma admits, identifies the sole issue to be tried as Salma's guilt, and lists 3 proposed exhibits and 2 witnesses that will testify on Salma's behalf in order to prove his innocence. The brief requests that trials be held on Fridays.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    90 views3 pages

    Pre Trial Brief

    Uploaded by

    barrystarr1
    Valz Demreeve P. Salma is accused of raping Yasmeen Junaid on March 17, 2014 at Escaño beach in Dumaguete City. Salma's defense counsel submitted a Pre-Trial Brief to the court admitting some facts but arguing that Salma is not guilty of rape. The brief outlines 8 facts that Salma admits, identifies the sole issue to be tried as Salma's guilt, and lists 3 proposed exhibits and 2 witnesses that will testify on Salma's behalf in order to prove his innocence. The brief requests that trials be held on Fridays.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 3

    Republic of the Philippines

    Regional Trial Court


    13th Judicial Region
    Branch 15
    Dumaguete City

    THE PEOPLE OF THE Criminal Case No. 38,390


    PHILIPPINES FOR: RAPE

    Complainant,

    -versus-

    Valz Demreeve P. Salma

    Accused,

    x---------------------------------------------x

    PRE-TRIAL BRIEF OF THE ACCUSED

    ACCUSED, through the undersigned counsel, before this


    Honorable Court, respectfully submits this Pre-Trial Brief:

    A. SUMMARY OF ADMITTED FACTS, AND PROPOSED


    STIPULATION OF FACTS

    The accused admits the following:

    1. That the Honorable Court has jurisdiction over the case;

    2. That the identity of the one charged in the information and that
    of the person arraigned is one and the same;

    3. That I am the defendant in the case;

    4. The identity of the offended party, Yasmeen Junaid;

    5. That Yasmeen Junaid is my girlfriend;

    6. That Yasmeen Junaid consented to the intimate acts that


    happened during the incident;

    7. That Yasmeen Junaid suggested that I marry her via text


    message, after the incident;

    8. That the incident took place on March 17, 2014 at around 6:30
    in the evening at Escaño beach, Dumaguete City.
    B. ISSUE TO BE TRIED

    Whether or not the accused is guilty of the crime charged.

    C. EVIDENCE FOR MARKINGS

    1. Affidavit of accused, Valz Demreeve P. Salma—Exhibit “F” a


    sworn written statement to prove that the acts of the accused did
    not constitute the crime of rape;

    2. Affidavit of witness, Andrea Bocelli—Exhibit “G” a sworn written


    statement to prove the relationship between the offended party
    and the defendant;

    3. Electronic evidence of several text messages exchanged between


    the offended party and the defendant before and after the
    incident—Exhibit “H” produced in print which contains the
    conversation between the offended party and the accused, and
    offended party’s suggestion of marriage after the incident.

    D. NAME OF WITNESSES

    1. Accused Valz Demreeve P.Salma—he will testify on his own


    behalf to prove his innocence;

    2. Andrea Bocelli—she is a friend of the accused and the offended


    party and he will testify on behalf of the accused.

    E. TRIAL DATES

    Specifically all Fridays of the month, with the regular


    appearance of theundersigned counsels before this Honorable Court.

    RESPECTFULLY SUBMITTED. April 20, 2014, Dumaguete City,


    Philippines.

    BENIGAY LAW OFFICE


    San Pedro Extension, Dumaguete City

    By:

    Atty. Precious Edlyn Benigay


    Defense Counsel
    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

    Copy furnished:
    PROS. FRANCIS GEORGE S. YAP
    City Prosecutor
    Dumaguete City Prosecution Office
    Hall of Justice
    Piapi, Dumaguete City

    PROS. ROSEL Q. ERAMES


    Asst. City Prosecutor
    Dumaguete City Prosecution Office

    Received by:___________
    Date: ___________

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