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PRE-TRIAL BRIEF FOR THE ACCUSED

Republic of the Philippines


MUNICIPAL TRIAL COURT IN CITIES
Eighth (8th) Judicial Region
Borongan City, Eastern Samar

PEOPLE OF THE PHILIPPINES,


Plaintiff,

CRIM. CASE NO. (2017-61)


1775
-versus-
FOR: ATTEMPTED HOMICIDE

SANTIAGO A. REDOA, SR.,


Accused.

/------------------------------------------------/

PRE-TRIAL BRIEF
FOR ACCUSED SANTIAGO C. REDOA, JR.

ACCUSED SANTIAGO A. REDOA, SR., by counsel,


most respectfully submits for the consideration of this
Honorable Court the following:

ADMITTED FACTS:

The defense admits:

1. The identity of the accused as to his demographics.


2. The jurisdiction of this Honorable Court

PROPOSED STIPULATION OF FACTS

Will the prosecution admit:

1. That there was no intent to kill by the accused in


inflicting the injuries to herein private complainant.

2. That based on the facts the mitigating


circumstance of vindication of a grave offense to
the ascendant of herein accused.

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PRE-TRIAL BRIEF FOR THE ACCUSED

3. That based on the acts, the mitigating circumstance


of having acted upon an impulse as powerful a
naturally to produced passion and obfuscation.

ISSUES TO BE TRIED OR RESOLVED

1. Whether or not the accused is criminally liable for


the crime of attempted homicide.

2. Whether or not there was intent to kill on the part


of herein accused

3. Whether or not any of the mitigating circumstances


under Article 13 of the Revised Penal Code may be
appreciated.

TESTIMONIAL EVIDENCE

1. Accused himself to refute the material allegations in


the complaint/information.
2. Dr. Roy C. Cayaco- to idemtidy the medical certificate.

AVAILABLE TRIAL DATES

To be agreed by the parties and counsels, subject to


the calendar of the Court.

Accused wishes to avail the privilege of continuous


trial.

RESPECTFULLY SUBMITTED. 10th day of November


2017 at Borongan City, Easter Samar Philippines.

Republic of the Philippines


PUBLIC ATTORNEYS OFFICE
Borongan District Office
Boronagn City, Eastern Samar

By:

ATTY. COREENE ANN G. CULAR


Public Attorney I/ Counsel for Plaintiff
Roll of Attorneys No. 67397

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PRE-TRIAL BRIEF FOR THE ACCUSED

IBP Member No. 004894 May 16, 2017, Manila


PTR No. 7646077 May 29, 2017, Tacloban
MCLE Compliance VI: On process

Copy Furnished:

HON. EDUARDO Q. ANG, JR.


Associate City Prosecutor
Borongan City, Eastern Samar

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