Republic of the Philippines

FIRST JUDICIAL REGION

REGIONAL TRIAL COURT
BRANCH 1
BAGUIO CITY
PEOPLE OF THE PHILIPPINES,
Plaintiff,
Criminal Case No.
___________
For: Serious Physical
Injuries
-versus-

KRISTEN GAY BANGANAN

Accused.
X----------------------------------------------------------x
PRE-TRIAL BRIEF
OF THE ACCUSED
WITH UTMOST DEFERENCE TO THE HONORABLE COURT
The Accused, by and through the undersigned counsel,
unto this Honorable Court, most respectfully submits this pre-trial
brief:
A. BRIEF STATEMENT OF THE ADMITTED FACTS
That the private complainant suffered physical injuries at
around 8 oclock in the evening of February 14, 2015 due a
squabble with the accused, and by reason thereof, was brought
to the hospital for treatment.
B.

PROPOSED STIPULATION OF FACTS

1. That there was a physical squabble between the
accused and the private complainant on February 14,
2015.
2. That the physical squabble resulted to the physical
injuries sustained by both parties.
3. That the private complainant sufficiently provoked the
accused to engage in such physical squabble by being

the first to inflict unlawful aggression, danger and

injuries upon the person of the accused.
4. That

the

accused

only

defended

herself

and

prevented the private complainant to inflict upon her

further injuries, and by averting anymore injuries,
inflicting upon the private complainant the injuries
complained of.
C. ISSUE/S:
Whether or not the prosecution proves that the accused
did not act in self-defense, thus guilty of the crime as charged.
D.

WITNESSES
1. _________________
2. ________________
3. __________________
4. Other witnesses are hereby reserved.

E. DOCUMENTARY EXHIBITS
1. _________________
2. ________________;
3. Accused reserved the right to present other documents as
may be found relevant and necessary in the course of the
trial.

F. TRIAL DATES
Specifically all Saturday of the month, with the regular
appearance of the undersigned counsels before this Honorable
Court.

Done in the City of Baguio, Philippines , February ___ , 2015.

RESPECTFULLY SUBMITTED.

RESPECTFULLY SUBMITTED.

Baguio City, Philippines, this ___ day of February 2015.

_________________________
Assistant City Prosecutor

_____________________
City Prosecutor

ATTY. Kahit sino

____________________ (ADdRESS) Baguio City
Tel No. (074) 324506
Counsel for the Defense
Roll No. XXXXXX/ 5-2-15
IBP. No. XXXXX / 12-29-15
MCLE Compliance No. XXXXXX / 12-20-15
PTR No. XXXXXX/ 01-05-15

Copy Furnished: ______________________

Assistant Prosecutor
Justice Hall, cor. Yandoc St. Baguio city