Professional Documents
Culture Documents
Pre Trial Brief
Pre Trial Brief
- versus –
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ACCUSED, through the undersigned counsel, before this Honorable Court, most
respectfully submit this Pre-Trial Brief:
1. Airline ticket
Purpose: To prove that the accused left Manila on 18 January 2019 bound to Dipolog city.
2. Certification of Philippine Airlines
Purpose: To prove that the accused was boarded PR 165 bound to Dipolog on 18 January
2019.
3. Photograph of the accused welcomed by constituents
Purpose: To prove that the accused was in Dipolog City on 18 January 2019.
4. Photograph of the accused with Mayor ERIKA B. JUMALON
Purpose: To prove that the accused was in Dipolog City on 18 January 2019.
5. Affidavit of Mayor ERIKA B. JUMALON
Purpose: To prove that the accused was in Dipolog City on 18 January 2019.
6. Photographs of accused and Ms. AVA S. TENDENILLA;
Purpose: To prove that the accused was in Dipolog City on 19 January 2019.
7. Affidavit of Ms. AVA S. TENDENILLA;
Purpose: To prove that the accused was in Dipolog City on 19 January 2019.
8. Affidavit of Ms. KATRINA S. LOZANO
Purpose: To prove that accused was in Dipolog City on 20 January 2019.
9. Photograph of accused attending the Brgy. Fiesta at Brgy. San Pedro
Purpose: To prove that accused was in Dipolog City on 20 January 2019.
10. Airline Ticket
Purpose: To prove that the accused was on board PR 165 bound to Manila on 25 January
2019.
ISSUES
WITNESSES
1. Accused Erick John Paul Pili Saysay to testify on the matters and circumstances attending
the raping of the victim;
2. Witnesses Erika B. Jumalon, Celine P. Golberg and Katrina S. Lozano to testify on the
presence of the accused was in Dipolog City;
3. Witness Celine S. Go to testify on the absence of the accused at No. 100, Shell Residences,
Pacific Drive, Sunset Avenue, Pasay City on January 19, 2019.
T RIAL DATES
Specifically all Fridays of the month, with the regular appearance of the undersigned
counsels before this Honorable Court.
RESPECTFULLY SUBMITTED.