Republic of the PhilippinesREGIONAL TRIAL COURTNational Capital Judicial RegionPasay City, Branch 98

THE PEOPLE OF THE PHILIPPINESComplainant,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 RESOLUTIONThe 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 STIPULATIONOther than those alleged in the Complaint-Affidavit, none at the moment.IV.DOCUMENTS TO BE PRESENTED1. 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 B3. 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 WITNESSES1. 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 RESOLVED1. Whether or not the Accused is guilty of violating Section 10 (a) of the R.A. 7610.

VII.APPLICABLE LAWS AND JURISPRUDENCE1. 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 TRIALThe 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

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LEIDA MAE BUMANLAG