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Republic of the Philippines

Sixth Judicial Region


REGIONAL TRIAL COURT
Branch___
Iloilo City

PEOPLE OF THE PHILIPPINES, CRIMINAL CASE NO._______


Plaintiff, FOR: MURDER

- versus -

GABRIEL SALAS, ALFREDO GOLEZ,


AND GREG FAJARDO,
Accused.
x-----------------------------------------------x

PRE-TRIAL BRIEF OF THE ACCUSED

ACCUSED, through the undersigned counsel, before this Honorable Court,


most respectfully submit this Pre-Trial Brief:

SUMMARY OF ADMITTED FACTS


AND PROPOSED STIPULATION OF FACTS

The accused admit the following:


1. the identities of those charged in the information and that of the
persons arraigned are one and the same;
2. the identity of Sulpicio Treyes, the victim;
3. the killing of the victim;
4. the date, place and time of the killing, which was May 5, 2008 at about
1:30 in the morning and at Corner Valeria-De Leon Sts., Iloilo City.

EVIDENCE FOR MARKINGS

1. Affidavit of accused, Gabriel Salas


Purpose: to prove that he admits the killing of the victim but the same was done
in self-defense;
2. Affidavits of accused, Greg Fajardo and Alfredo Golez
Purpose: to prove that they were at the place where the crime was committed
but have no participation thereof;
3. Medical Report issued by Dra. Cielo F. Eltonn, M.D. to Gabriel Salas
Purpose: to prove that the accused sustained several wounds as a result of the
aggression by the victim;
4. Blotter Report of Molo Police Station (ICP-PP4)
Purpose: to prove that the accused Gabriel Salas voluntarily surrendered to the
Police authorities.

ISSUES

1. Whether or not the accused committed the crime charged;

2. Whether or not they were guilty thereof.

WITNESSES

1. Accused Gabriel Salas to testify on the matters and circumstances


attending the killing of the victim;
2. Accused Alfredo Golez and Greg Fajardo to testify on their non-
participation on the killing;
3. Witness Jason Pilas-Pilas to testify on the exchange of words and blows
between the accused Gabriel Salas and the deceased which resulted to the
death of the victim;
4. Dra. Cielo F. Eltonn, M.D. to testify on the veracity of the findings
stated in the medical report of Gabriel Salas.

TRIAL DATES

Specifically all Fridays of the month, with the regular appearance of the
undersigned counsels before this Honorable Court.

RESPECTFULLY SUBMITTED.

Iloilo City, Iloilo, Philippines, June 2, 2008

GALLEGO-SABIDO LAW OFFICES


Arguelles St., Jaro, Iloilo City

By:

RHONALYN C. GALLEGO
Counsel for the Defense
Roll No. 68999 / 5-2-07
IBP. No. 789084 / 12-29-07
MCLE Compliance No. 890590 / 12-20-07
PTR No. 345667 / 01-05-08
And

EVANGELINE S. SABIDO
Counsel for the Defense
Roll No. 69009 / 5-2-07
IBP. No. 789085 / 12-29-07
MCLE Compliance No. 890591 / 12-20-07
PTR no. 345668 / 01-05-08

Copy furnished:

PROS. SHYR PHOEBE F. REGUETA


Assistant City Prosecutor
Ramon Q. Avanceña Hall of Justice
Bonifacio Drive, Iloilo City

Received by:___________
Date: ___________