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    Pre Trial Brief For The Accused Template

    Uploaded by

    Eugene Albert Olarte Javillonar
    The pre-trial brief summarizes a criminal case of concubinage against Mr. Elias Macatol and Ms. Magdalena Pinili. It outlines stipulated facts, including that Mr. Macatol is lawfully married, Ms. Pinili is a lesbian in a relationship with Ayra Batacan, and Ms. Pinili works as a household helper for Mr. Macatol. The brief also lists proposed evidence and witnesses to argue that no intimate relationship exists between Mr. Macatol and Ms. Pinili beyond employer and employee. The defense is open to settlement but ready for trial on the proposed dates.

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    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd

    Pre Trial Brief For The Accused Template

    Uploaded by

    Eugene Albert Olarte Javillonar
    70 views4 pages
    The pre-trial brief summarizes a criminal case of concubinage against Mr. Elias Macatol and Ms. Magdalena Pinili. It outlines stipulated facts, including that Mr. Macatol is lawfully married, Ms. Pinili is a lesbian in a relationship with Ayra Batacan, and Ms. Pinili works as a household helper for Mr. Macatol. The brief also lists proposed evidence and witnesses to argue that no intimate relationship exists between Mr. Macatol and Ms. Pinili beyond employer and employee. The defense is open to settlement but ready for trial on the proposed dates.

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    Pre Trial Brief for the Accused Template

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    The pre-trial brief summarizes a criminal case of concubinage against Mr. Elias Macatol and Ms. Magdalena Pinili. It outlines stipulated facts, including that Mr. Macatol is lawfully married, Ms. Pinili is a lesbian in a relationship with Ayra Batacan, and Ms. Pinili works as a household helper for Mr. Macatol. The brief also lists proposed evidence and witnesses to argue that no intimate relationship exists between Mr. Macatol and Ms. Pinili beyond employer and employee. The defense is open to settlement but ready for trial on the proposed dates.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    70 views4 pages

    Pre Trial Brief For The Accused Template

    Uploaded by

    Eugene Albert Olarte Javillonar
    The pre-trial brief summarizes a criminal case of concubinage against Mr. Elias Macatol and Ms. Magdalena Pinili. It outlines stipulated facts, including that Mr. Macatol is lawfully married, Ms. Pinili is a lesbian in a relationship with Ayra Batacan, and Ms. Pinili works as a household helper for Mr. Macatol. The brief also lists proposed evidence and witnesses to argue that no intimate relationship exists between Mr. Macatol and Ms. Pinili beyond employer and employee. The defense is open to settlement but ready for trial on the proposed dates.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
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    Republic of the Philippines

    MUNICIPAL TRIAL COURT


    Baganga, Davao Oriental

    PEOPLE OF THE PHILIPPINES, CRIMINAL CASE NO. 3002-


    Plaintiff, 2017-CR

    -versus- FOR: CONCUBINAGE

    MR. ELIAS MACATOL and


    MS. MAGDALENA PINILI
    Accused.
    x-----------------------x

    PRE-TRIAL BRIEF FOR ACCUSED

    THE ACCUSED, through the undersigned Counsel, before this Honorable


    Court, most respectfully submits this Pre-Trial Brief:

    SUMMARY OF ADMITTED FACTS AND PROPOSED STIPULATION


    OF FACTS

    The following are the proposed stipulation of facts:


    1. The accused has two children with MILAGROS D. BALICAN-
    MACATOL namely Julie Anne and Joana May.
    2. The accused and MILAGROS D. BALICAN-MACATOL were
    lawfully married at the Immaculate Concepcion Parish.
    3. That MAGDALENA PINILI is a homosexual, namely a lesbian who
    has a romantic relationship with one AYRA BATACAN.
    4. That MAGDALENA PINILI is the childhood friend and household
    helper of the accused receiving a fixed monthly salary from him.
    ISSUE TO BE TRIED

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

    EVIDENCE FOR MARKING

    1. Affidavit of the accused marked as “Exhibit 1”


    Purpose: To prove that the accused does not have any intimate
    relationship nor any kind of relationship with Magdalena Pinili
    except that of a Household Employer.
    2. Affidavit of Magdalena Pinili, marked as “Exhibit 2”
    Purpose: To prove that the she is and has been a lesbian since
    childhood who has interest only on people of the same gender as her,
    namely, women.
    3. Affidavit of Ayra Batacan marked as “Exhibit 3”
    Purpose: To prove that Magdalena Pinili is a homosexual lesbian
    who is in a relationship with her and that Magdalena Pinili has been
    a homosexual ever since her early Childhood.

    WITNESSESS
    1. Accused Elias Macatol to testify that he has no any sort of
    relationship with Magdalena Pinili
    2. Magdalena Pinili to testify that she is a homosexual lesbian since
    childhood and has interests only on people of the same gender as
    hers.
    3. Ayra Batacan to corroborate the testimony of Magdalena Pinili that
    she is a lesbian and to prove that the latter has a romantic
    relationship with the affiant.
    POSSIBILITY OF AMICABLE SETTLEMENT
    That the accused is open and willing to submit this case to any alternative
    mode of dispute settlement and likewise they are willing to settle this case
    amicably provided that the terms and conditions thereof are fair and
    reasonable.

    AVAILABLE TRIAL DATES


    The undersigned counsel is available for trial on any of the dates of January
    3, 18, and 30, 2018. The undersigned counsel also respects the calendar of
    this Honorable Court and agrees to other dates that may be set during the
    pre-trial as may be convenient to the counsel for the plaintiff and the
    Honorable Court.

    RESPECTFULLY SUBMITTED
    Respectfully submitted this 06 January 2018 at Baganga, Philippines.

    Alpas, Lomondot & Jardinel Law Firm


    Room D-100, Dotterweich Building
    E. Jacinto Street, Davao City
    By:

    Atty. ALPAS, FRANCIS ANTHONY CRIS


    C.
    Counsel for the Defense
    Roll No. 33333 / 03-03-2018
    IBP No. 181818 / 03-03-2019
    MCLE Compliance No. 181833 / 03-2018
    PTR No. 1818333/ 3-18-2018

    and

    Atty. LOMONDOT, SARAH JANE


    Counsel for the Defense
    Roll No. 128374 / 09-01-2018
    IBP No. 283984 / 10-20-2019
    MCLE Compliance No. 287364 / 3-2-2018
    PTR No. 273837/ 12-29-2019

    Copy furnished by personal service:


    ATTY. MEL CATHERINE MIRANDA
    Prosecutor III
    Davao City Prosecution Office

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