Republic of the Philippines

Supreme Court
10th Judicial Region
Municipal Trial Court in Cities
Cabadbaran City, Agusan del Norte

People of the Philippines Crim Case No. ______

Plaintiff, FOR:
“ CONCUBINAGE”

-versus-

___________________ and
_____________________
Accused/s.

x---------------------------------------x

PRE-TRIAL BRIEF OF JUMAR B. COLON

COMES NOW, Accused Jumar B. Colon, through the
undersigned counsel, unto this Honorable Court, most respectfully
submit her pre-trial brief and state:

1. WILLINGNESS TO ENTER INTO AN AGREEMENT

Accused is open for settlement.

2. BRIEF STATEMENT OF THE ACCUSED CLAIMS AND

DEFENSES

Accused Jumar B. Colon is not living in together with her co-

accused Stephanie Cagadas. Witnesses can testify to the fact that
Stephanie Mae Cagadas is living with her parents in Brgy.
Kauswagan, Cabadbaran City, Agusan del Norte and not with his
co-accused.

3.Number of Witnesses to be presented

The accused with reservation ( IBP just assigned the

case to herein counsel on January 17, 2018 and to give time for the
counsel to prepare , study and secure witnesses for the case of
herein accused)

4. Statement of the Issues

 Whether or not accused is guilty beyond reasonable doubt of
the crime charged.

5. Documents to be presented

Judicial Affidavits of witnesses ( neighbour, relatives,

friends)

With reservation

6. ADMISSIONS/PROPOSED STIPULATIONS

a. Will the prosecution admit that both accused did not live together
as husband and wife?

b. Will the prosecution admit that accused witness Ritchel D.

Corvera’s house from accused Stephanie Mae Cagadas is far from
her house?.

7. APPLICALE LAWS AND JURISPRUDENCE

Revised Penal Code of the Philippines

8. AVAILABLE TRIAL DATES

We submit to the court calendar’s available dates and or to be

agreed by counsel during the hearing.

9. OTHER MATTERS

Should there be a trial, accused pray to submit the judicial

affidavit of its witnesses at least three days prior to the presentation
of the witness.

Most respectfully submitted.

January 18, 2017

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