REPUBLIC

OF THE PHILIPPINES REGIONAL TRIAL COURT BRANCH 10 MAKATI CITY CRIM CASE NO. 00001-13, 00002-13, & 00003-14, ADMINISTRATIVE CASE NO. 0004-13 BIANCA SIMEON y MONDRAGON, Complainant, -versus- BENIGNO SIMEON, Accused. xx MEMORANDUM FOR THE PROSECUTION Bianca Simeon y Mondragon, by the undersigned prosecutors, and unto this Honorable Court, respectfully submits this Memorandum as follows: PREFATORY STATEMENT In May 2013, complainant Bianca Simeon discovered during her trip to Cebu City that her husband and herein accused, Benigno Simeon, was married to another woman, Shalani Simeon, with whom he has a one year old son. Upon her return to Manila, complainant likewise discovered that her daughter, Bernadette Mondragon, was raped and impregnated by the accused sometime in March 2013. Benigno Simeon once again attempted to rape the minor in April 2013. The accused is hereby charged with rape, attempted rape, bigamy, and a prayer for disbarment. The prosecution humbly states and takes the position that it has presented competent witnesses, clear, convincing and sufficient evidence to prove beyond reasonable doubt that accused is guilty of committing the crimes charged and that the accused miserably failed to present any evidence that could even raise an iota of doubt as to their guilt of the offenses charged. The Supreme Court has once said that rape is a nauseating crime that deserves the condemnation of all decent persons who recognize that a womans cherished chastity is hers alone to surrender of her own free will. Whoever violates that will descend to the level of the odious beast.1 STATEMENT OF FACTS 1. On December 20, 2010, Bianca Mondragon (a widow) married Benigno Simeon at the Santuario de San Antonio in Makati City. 2. Complainant Bianca Simeon works as a sales executive and she travels not only around Metro Manila but also to other parts of the Philippines where they have