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Republic of the Philippines

REGIONAL TRIAL COURT


National Capital Judicial Region
Pasay City, Branch 98
THE PEOPLE OF THE
PHILIPPINES
Complainant,
Criminal Case No. 38, 390-15
FOR: Violation of Section 10 (a),
Article VI of Republic Act No. 7610
-versus-

RONALD VERDUGO
Accused.
x--------------------------------x

PRE-TRIAL BRIEF
Comes now Private Complainant CARLA CRUZ, by and thru the
undersigned private prosecutor, under the direct and supervision of
the Honorable Public Prosecutor, and unto this Honorable Court,
most respectfully manifests and states that:
I.
BRIEF STATEMENT OF COMPLAINANTS DEFENSE
This is an action against Accused Ronald Verdugo, to be
convicted for violation of Section 10 (a), Article VI of Republic Act
No. 7610 otherwise known as Special Protection of Children
Against Abuse, Exploitation and Discrimination Act. Herein
Accused did then and there willfully, unlawfully, feloniously,
physically and verbally abuse my daughter Anna Cruz.
II.
POSSIBILITY OF AMICABLE SETTLEMENT OR
ALTERNATIVE MODES OF DISPUTE RESOLUTION

The Private Complainant is not willing to consider any amicable


settlement or undergo alternative modes of dispute resolution with
respect to the primary prayer of this petition.
III.
ADMISSION AND STIPULATION
Other than those alleged in the Complaint-Affidavit, none at
the moment.
IV.
DOCUMENTS TO BE PRESENTED
1. Certificate of Live Birth of Anna Cruz, proving that she is still a
minor as EXHIBIT A.
2. Photos of wounds and bruises of Anna Cruz while living with the
Accused as EXHIBIT B
3. Medical Certificate issued by Dr. Santos of Philippine General
Hospital after conducting a medical examination of the child.
This tends to show that she has been physically abused and
malnourish as EXHIBIT C.
IV.
NAMES OF WITNESSES
1. CARLACRUZ will testify as to the truthfulness of her allegations
in the Complaint-Affidavit.
2. ANNA CRUZ will testify as to the truthfulness of being a victim to
herein case.
3. MERCEDITAS SANDOVAL will testify as an eye witness to the
case.
VI.
ISSUES TO BE TRIED AND RESOLVED
1. Whether or not the Accused is guilty of violating Section 10 (a) of
the R.A. 7610.
VII.

APPLICABLE LAWS AND JURISPRUDENCE


1. 1987 Philippine Constitution;
2. R.A. 7610 otherwise known as Special Protection of Children
Against Abuse, Exploitation and Discrimination Act;
3. Jurisprudence laid down by the Supreme Court in relation to
R.A. 7610 otherwise known as Special Protection of Children
Against Abuse, Exploitation and Discrimination Act.
VII.
AVAILABLE DATES FOR TRIAL
The Complainant respectfully requests that the trial dates be
agreed upon in open court at such dates and time convenient to the
parties and calendar of this Honorable Office.

WHEREFORE, premises considered, it is respectfully prayed unto


this Honorable Office that the foregoing Pre-Trial Brief be duly
noted.
Respectfully Submitted.
City of Manila for Pasay City. 13 February 2015.

Assisted by counsel:

LEIDA MAE BUMANLAG


ROLL OF ATTORNEYS NO. 56789
IBP Lifetime No. 08888/Manila III
PTR NO. 77777/Jan. 7, 2015/MLA
MCLE Compliance: IV-0002279/20 January 2012
Copy Furnished and Explanation
JASREEL DOMASING
No. 1068 Block 16, Kabisig
Brgy. San Andres
Cainta, Rizal

The filing and/or service of the foregoing is/are via registered mail or
alternative courier due to absence of manpower to effect personal filing and/or
service and/or due to the distance involved and time constraints. (Please
disregard if the filling and/or service was/were effected personally.)

LEIDA MAE BUMANLAG