Republic of the Philippines

Sixth Judicial Region

REGIONAL TRIAL COURT
Branch___
Iloilo City

PEOPLE OF THE PHILIPPINES, CRIMINAL CASE NO.17-719

Plaintiff,
FOR:
MALVERSATION OF PUBLIC FUNDS
Article 217 of Revised Penal Code

- versus -

VICENTE QUELESTE Y MARABARA

Accused.

x-----------------------------------------------x

PRE-TRIAL BRIEF OF THE DEFENSE

VICENTE QUELESTE Y MARABARA, through the undersigned Atty. Nestor

Jeremy B. Moreno and Atty. May Leony Jalipa, before this Honorable Court, most
respectfully submit this Pre-Trial Brief:
SUMMARY OF ADMITTED FACTS
AND PROPOSED STIPULATION OF FACTS
The following are the admitted facts:
1. the identity of the person charged in the information and that of the
person arraigned are one and the same;
(to be deleted)
2. the place of office of the person charged;
3. the position in the Government Office of the person charged;
4. the date of the COA Examination.
The following are the proposed stipulation of facts:
1. That there was no thorough conduct of cash examination as the COA
Auditors did not cash examine all the accountable officers in the Office
of the Municipal Treasurer of the Municipality of Zarraga, Iloilo on the
date of the COA Examination;
2. That there was no demand sent to the Accountable Officer for the
immediate production of the missing fund(s).

EVIDENCE FOR MARKINGS

1. Judicial Affidavit of Mr. Vicente Queleste y Marabara (Exhibit 1)
Purpose: to prove that no crime was committed;
 2. Judicial Affidavit of Mr. Allistair Shadow Moon (Exhibit 2)
Purpose: to confirm the truthfulness of the allegations of the accused;
3. Judicial Affidavit of PETYR SUNSHINE BAELISH (Exhibit 3)
Purpose: to confirm the truthfulness of the allegations of the accused;
4. Judicial Affidavit of LUISA MARIA DE JESUS (Exhibit 4)
Purpose: to confirm the truthfulness of the allegations of the accused.

ISSUES
1. Whether or not the accused committed the crime charged;
2. Whether or not he is guilty thereof.

WITNESSES
1. Mr. Vicente Queleste y Marabara to testify that he was innocent of the
crime charged;
2. Mr. Allistair Shadow Moon to testify on the truthfulness of the allegations
of the accused and on the facts surrounding the case;
3. PETYR SUNSHINE BAELISH to testify on the truthfulness of the
allegations of the accused and on the facts surrounding the case;
4. LUISA MARIA DE JESUS to testify on the truthfulness of the allegations
of the accused and on the facts surrounding the case.

TRIAL DATES
Specifically all Fridays of the month, with the regular appearance of the
undersigned defense lawyer before this Honorable Court.
RESPECTFULLY SUBMITTED.
Iloilo City, Iloilo, Philippines, August 2, 2017.

ATTY. NESTOR JEREMY B. MORENO

Defense Lawyer
Roll No. 40232-1990
IBP. No. 783323
MCLE COMPLIANCE III No. 0013434
PTR No. 4234434
Issued on April 22, 2016

And

Atty. MAY LEONY JALIPA

Defense Lawyer
Roll No. 23111- 2000
 IBP No. 982231
MCLE COMPLIANCE II No. 000321
PTR No. 9213399
Copy furnished:

ATTY. Deanne Mitzi Somollo

Counsel for the Prosecution

Received by:___________
Date: ___________