REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

Sixth Judicial Region
Branch 63, Iloilo City

PEOPLE OF THE PHILIPPINES

Plaintiff, CRIM. CASE NO. 17-1234 &18-5678
For: Viol. Of SEC. 5(i) of R.A. No. 9262
-versus- & Viol. Of SEC. 5(i) in rel. to Sec. 3(c)
of R.A. No. 9262

RONEL CARSON
Accused.
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PRE-TRIAL GUIDE

BRIEF STATEMENT OF THE DEFENSE OF THE ACCUSED

The defense of the accused is Denial because the statement of facts alleged to
exist does not actually exist.
That the economic abuse where the psychological abuse stands does not exist
since accused is in fact willing to provide financial support to his child whatever the
result of this case.

PLEA BARGAINING

None.

STIPULATION OF FACTS

A. Proposed Stipulation of Facts

Will the prosecution admit:

1. That the monthly scheduled financial support every month was stopped only last March
2016.
2. That the accused offered to send material things to his child, instead of cash.
3. That the financial support was stopped because private complainant and her mother
threatened to use the money to file a case against the accused?
4. That on March 26, 2018, a second information having the same cause of action was filed
again before the Regional Trial Court branch 63?

MARKING AND IDENTIFICATION OF EVIDENCE OF THE PARTIES

Exhibit A --- Palawan receipts evidencing monthly financial support; (Reserved)

Exhibit B --- Print screen of Facebook messages from messenger showing that
Complainant threatened to file a case using accused money;
(Reserved)

Exhibit C --- Print screen of Facebook messages from messenger showing that Accused
offered to send materials things to his child instead of sending cash
because complainant threatened to file a case using said cash;
 Exhibit D --- Sworn statement of Private complainant stating that she learned about
the alleged paramour from her friend, not from her housekeeper;

The accused hereby reserves the right the present additional documentary evidence
which are relevant to the testimony of the witnesses for the prosecution;

WAIVER OF OBJECTIONS TO ADMISSIBILITY OF EVIDENCE

None

MODIFICATION OF THE ORDER OF TRIAL IF THE ACCUSED ADMITS THE

CHARGE BUT INTERPOSES A LAWFUL DEFENSE

None

SUCH MATTERS AS WILL PROMOTE A FAIR AND EXPEDITIOUS TRIAL OF THE

CRIMINAL AND CIVIL ASPECTS OF THE CASE

None

ISSUES
1. Whether or not the accused is guilty of violation of Viol. Of SEC. 5(i) of R.A.
No. 9262 or Economic abuse
2. Whether or not the accused is guilty of violation of Viol. Of SEC. 5(i) in rel. to
Sec. 3(c) or psychological abuse.

WITNESSES TO BE PRESENTED

The defense will present the following witnesses:

1. Ronel Carson – the accused

2. –
3. –

Reservation

Accused expressly reserves the right to present such additional witnesses and
other exhibits and evidence as the exigencies of the trial may require.

SPECIFIC TRIAL DATES