Republic of the Philippines

REGIONAL TRIAL COURT

6TH JUDICIAL REGION
BRANCH 62, BAGO CITY

PEOPLE OF THE PHILIPPINES CRIM CASE NO 123

Complainant (NPS NO. 123)

-versus- -For-

-Murder-
ROBERTO RONILO y DELFIN
Accused

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PRE-TRIAL BRIEF OF THE DEFENSE

The Accused, represented by the undersigned counsel as his attorney-in-law,

respectfully submits to this Honorable Court this Pre-Trial Brief, to wit:

I.

PROPOSED STIPULATION OF FACTS

The defense proposes the following stipulation of facts:

1. That the accused, Rodrigo Ronilo y Delfin, is a former overseas Filipino

worker from the State of Dubai who prior to the case was residing in Bago
City.
 2. That the private complainant claims That the accused, with treachery and
abuse of superior strength, intently slashed, hacked and stabbed the accused
causing his untimely death That the accused denies the claim of the private
complainant that with grave abused of confidence reposed upon her took the
said amount with intent to gain.
3. That the accused did not in fact commit the actions accused of him on the
ground that he was in employed in the State of Dubai as an Electronic
Engineer under the Ali Punga Company during the time.
4. That the it was his brother Roberto Ronilo who allegedly committed the
actions that led to the death of the victim.
5. That he was arrested by the authorities with the belief that it was his brother
that they were arresting, and that the accused kept silent during the time.
6. That the accused had every intention to protect his brother’s wellbeing and to
be punished in his place, but now comes to this court with a change of mind
and heart.

II.

ISSUES TO BE TRIED AND RESOLVED

The Defense proposes the following issues to be tried and resolved by this

Honorable Court:

1. Whether or not the elements of the crime charged are all present in the

case.

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

 3. Whether or not the true identity of the person responsible for the

criminal act is the accused.

III.

Applicable Laws and Jurisprudence

A. Revised Penal Code

B. Jurisprudence laid down by the Supreme Court

The opposition respectfully reserves the right to cite applicable laws and
jurisprudence as the case progresses.

IV.

EVIDENCES TO BE MARKED

The Opposition will present the following documents

1. The Official Passport of the accused evidencing that he was in Dubai

during the time of the commission of the offense.

 2. The Birth Certificate of the Accused and his Brother to prove that

they are different persons

3. Family Photos to show the similarities between the accused and his

brother.

4. Other documents as may be determined to be relevant to the case

during the course of trial.

V.

WITNESSES TO BE PRESENTED

The Opposition will present the following witnesses:

1. Rodrigo Ronilo, as witness to himself.

2. Andrea Delfin, the Aunt of the accused and his brother, to prove the

identity of the accused and his brother are not one in the same.

3. Other witnesses as may be determined to be relevant to the case

during the course of trial.

VII.

AVAILABLE DATES FOR TRIAL

The defense respectfully requests that the trial dates be agreed upon in open

court at such dates and time convenient to the parties and the calendar of this

Honorable Court.
 WHEREFORE, premises considered, it is respectfully prayed unto this

Honorable Court that the foregoing Pre-Trial Brief be duly noted.

Bago City, April 3, 2014.

Counsel for the Defense

Atty. Joshua William D. Su

Atty. Mj Decolongon

Atty. Robert Navarez

Atty. Saviya Bassille Albestor

Copy Furnished