Republic of the Philippines

Sixth Judicial Region

FAMILY COURT
Branch ___
Ramon Q. Avancea Hall of Justice
Iloilo City

PEOPLE OF THE PHILIPPINES,

Plaintiff,

-versus- Criminal Case No. ____

For: Violation of RA
9262
KAZPER BERMEJO, Violence against
Accused. Women and Children
x---------------------------------------------x

PRE-TRIAL BRIEF OF THE PROSECUTION

THE PEOPLE OF THE PHILIPPINES, through the

undersigned City Prosecutor, before this Honorable Court, most

respectfully submit this Pre-trial Brief:

SUMMARY OF ADMITTED FACTS

AND PROPOSED STIPULATION OF FACTS
The following are the admitted facts:
1. The identity of the accused charged in the information and

that of the person arraigned is one and the same;

2. That private complainant Rhenee Peniano-Bermejo, of legal

age, and accused Superintendent Kazper Bermejo, of legal

age, were married and residing in #45 Yulo St., Arevalo, Iloilo

City;
3. That Rhenee Peniano-Bermejo and Superintendent Kazper

Bermejo have two (2) children, namely: the first child is Juan

Bermejo who is six (6) years old and the second child is

Patricia Bermejo who is four (4) years old;

4. That the eldest child Juan Bermejo is currently enrolled as

Kinder II at Holy Rosary Academy, Inc. while the second child

Patricia Bermejo is currently enrolled as Prep in the same

school;
5. That while he was in Armed Forces of the Philippines

assigned at Camp Bonifacio, Taguig City, the Accused used

to regularly go home and visit his family;

6. That accused was transferred service to PNP and was

assigned to Kalibo Police Station in Kalibo, Aklan starting in

August 2014;
7. That the accused has the rank of Superintendent with salary

grade 25;
8. That the accused is currently receiving P54,000.00 monthly

basic salary and P15,000.00 in allowances;

9. That Private Complainant sent a letter on January 12, 2016

addressed to former PNP Chief CDG Alan Purisima requesting

for sub-allotment of allowances intended for the two (2)

children;
10. That Private Complainant and Accused ended up

entering into a Memorandum of Agreement which was

executed on March 18, 2016 in Roxas City with a stipulation

that Accused shall give a total amount of Ten Thousand

(P10,000.00) Pesos per month divided as Five Thousand

(P5,000.00) Pesos for every child and additional Five

Thousand (P5,000.00) Pesos for the childrens education; and

11. That private complainant sent a Demand Letter

requesting that the amount of Fifteen Thousand (P

15,000.00) Pesos shall be directly deducted from the net pay

of my husband every month and this amount to be sent in

the form of a check;

EVIDENCE FOR MARKING

1. Affidavit of the Private Complainant as Exhibit A;

2. Copy of the Marriage Certificate between Rhenee Peniano-

Bermejo and Kazper Bermejo as Exhibit B;

3. Copies of their Certificates of Live Birth of the two children

Juan Bermejo and Patricia Bermejo as Exhibits C and D

respectively;
4. Copies of the receipts of the tuition fees for the two

children as Exhibit E for Juan Bermejo and Exhibit F for

Patricia Bermejo;
5. Copy of the Certificate of Employment of the accused as

Exhibit G;
6. Copy of the letter on January 12, 2016 addressed to

former PNP Chief CDG Alan Purisima requesting for sub-

allotment of allowances intended for our two (2) children

as Exhibit H;
7. Copy of the Memorandum of Agreement which was

executed on March 18, 2016 in Roxas City with a

stipulation that Accused shall give a total amount of Ten

Thousand (P10,000.00) Pesos per month divided as Five

Thousand (P5,000.00) Pesos for every child and additional

Five Thousand (P5,000.00) Pesos for the childrens

education as Exhibit I;
8. Copy of the Demand Letter in the amount of Fifteen

Thousand (P 15,000.00) Pesos to be directly deducted

 from the net pay of the Accused and the amount to be

sent to me in the form of a check as Exhibit Annex J;

9. Copy of the marriage certificate between Faith Cuneta and

Kazper Bermejo dated June 30, 2015 as Exhibit K;

ISSUES
Whether or not the Accused committed violation of Section 5 par.
e (2) in relation to Section 3 par. a, sub. par. D of RA 9262
(economic abuse)

WITNESSES
1. Rex Tupas No. 123 Jaro, Iloilo City

2. Kesh Pesina #45 Yulo St., Arevalo, Iloilo City

3. Maria Peniano-Bermejo #45 Yulo St., Arevalo, Iloilo City

TRIAL DATES
Specifically all Saturdays of the month, with the regular
appearance of the undersigned city prosecutor before this
Honorable Court.
RESPECTFULLY SUBMITTED.
Iloilo City, Philippines; January 5, 2017.

ILOILO CITY PROSECUTORS

OFFICE
Ramon Q. Avancena Hall of
Justice
 Iloilo City
By:

ROBERT IAN MARANON

City Prosecutor
Roll of Attorneys No. 12345
IBP No. 67890/Iloilo City/4-3-
2015
MCLE Exempt
PTR Exempt

Copy furnished through personal service:

Atty. Josefa Castro

Counsel for the Accused
Iloilo City
Date: ____________
Time: ____________