REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

NATIONAL CAPITAL JUDICIAL REGION
MANILA CITY, BRANCH __

PEOPLE OF THE PHILIPPINES

Plaintiff,

-versus- Criminal Case No. __________

For: Serious Illegal Detention
LADY TREMAINE
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 admits the following:

1. The identity of the person charged in the information and that of the person arraigned is one
and the same;
2. The identity of Princess Cinderella, the victim;
3. The detention of the victim; and
4. The date, time and place of the detention, which was January 15, 2018 at about 5:30 in the
afternoon and at 12 Midnight St., Sampaloc, Manila.

EVIDENCE FOR MARKINGS

1. Affidavit of accused, Lady Tremaine

Purpose: to prove that she admits the detention of the victim but the same was done in order to avoid
greater evil or injury;
2. Affidavit of Conchita P. HIthit
Purpose: to prove what actually transpired on January 1, 2018 at Bonifacio Global City and to prove the
authenticity of the photos taken by her during the party on said date and place;
3. Drug test results of Princess Cinderella on November 31, 2014 and November 31, 2015, and
Certificate of Completion of rehabilitation
Purpose: to prove that Princess Cinderella had history of using drugs and had been confined to
rehabilitation center twice and to prove the complainant’s propensity for violence due to her addiction;
4. Pictures taken by Conchita Hithit using her phone during the party on January 1, 2018
Purpose: to prove that there was actually drug session;
5. Medical Certificate and Medico-Legal Certificate issued by Dr. Fairy Godmother and Dr. Joel
Macapino respectively
Purpose: to prove that the accused sustained several wounds as a result of the aggression by the victim;
 6. CCTV footages with date and time stamp captured on January 15, 2018
Purpose: to prove the aggression of the victim towards the accused and to show the actual date and
time of the occurrence of the incident;
7. Picture of the attic door and lock
Purpose: to show the type of lock involved, the aftermath of the incident, the trail of blood left by Lady
Tremaine, indicating the struggle to close the door, and to show that it matches the door captured by the
CCTV camera during the incident;
8. Broken pieces of glass slipper found at the place of incident and those removed from the
accused’s head
Purpose: to prove the material used by the victim to hit the accused;
9. Affidavit of Lucy F. Ukrat
Purpose: to prove the existence of the white tablet found inside the attic;
10. White tablet found in the attic
Purpose: to prove that the victim was using drugs; and
11. PDEA Chemistry Report
Purpose: to prove that the white tablet contains Methylenedioxymathamphetemine, a dangerous drug
under R.A. 9165.

ISSUES

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

2. Whether or not the act constituting the crime charged was justified under Article 11,
paragraph 4 of the Revised Penal Code; and
3. Whether or not she was guilty thereof.

WITNESSES

1. Accused Lady Tremaine to testify on the matters and circumstances attending the detention
of the victim.
2. Witness Conchita P. Hithit to testify on what actually transpired on January 1, 2018 at
Bonifacio Global City.
3. Witness Lucy F. Ukrat to testify on the matters and circumstances attending the discovery of
the white tablet inside the attic.

TRIAL DATE

Specifically all Tuesdays of the month, with regular appearance of the undersigned counsel
before this Honorable Court.

RESPECTFULLY SUBMITTED.

Sampaloc, Manila City, Philippines, February 13, 2018

JERMILE SALOR
Counsel for the Defense
Roll no. 12345
IBP No. 654321 / 12-20-15
MCLE Compliance No. 555334
 PTR No. 345667

Copy Furnished:

PROS. JUAN DELA CRUZ

Assistant City Prosecutor
Manila City Hall of Justice
Manila City

Received by:____________
Date: _____________