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Republic of the Philippines

Sixth Judicial Region

Regional Trial Court

Branch 62

Republic of the Philippines, Criminal Case No. 16-1782639

Complainant, For: Acts of Lasciviousness

In Relation to R.A 7610

-versus-

Dino Patchouli,

Accused.

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

PRE-TRIAL BRIEF FOR THE PROSECUTION

The People of the Philippines, through the Office of the City Prosecutor, unto this
Honorable Court, most respectfully submits this Pre-Trial Brief:

SUMMARY OF ADMITTED FACTS

AND PROPOSED STIPULATION OF FACTS

The following are the admitted and proposed stipulation of facts:

1. The identity of the person charged in the information and that of the person
arraigned are one and the same;
2. The identity of Tara Jane Pot-Pot, the victim;
3. The age of the victim, which is 17 years old;
4. That the accused is an adult;
5. The date and places of the commission of the crime, which is the 26 th day of June,
2014 at Barangay Ilijan, Bago City;
6. That the accused and the victim are neighbors in Barangay Ilijan, Bago City.

EVIDENCE FOR MARKING

1. Affidavit of the Private Complainant, Tara Jane Pot-Pot


Purpose: To prove that the accused committed Acts of Lasciviousness against her
person with lewd designs, through force, threat and intimidation and taking
advantage of her minority.
2. Blotter Report of the Bago City Police Station
Purpose: To prove that the private complainant has filed a complaint against the
accused for committing Acts of Lasciviousness against her.
3. Electronic copy of the CCTV Camera footage of Aling Nenas Supermarket
Purpose: To verify the presence of the accused at the scene of the crime.
4. Certificate of Live Birth of the Private Complainant, Tara Jane Pot Pot
Purpose: To prove the minority of the victim at the time of the commission of the
crime as charged.
5. Certificate of Live Birth of the Accused, Dino Patchouli
Purpose: To prove that the accused is of age and an adult at the time of the
commission of the crime as charged.
6. 2010 Updated COMELEC Voters List for Brgy. Ilijan, Bago City
Purpose: To prove that the accused is not a minor at the time of the commission of
the crime.
7. Sworn Affidavit of Witness, Superman Batman
Purpose: To prove the circumstances surrounding the apprehension of the accused
following the commission of the crime as charged.
8. Sworn Affidavit of Witness, Flash Aquaman
Purpose: To prove the circumstances surrounding the apprehension of the accused
following the commission of the crime as charged.
9. Digitally Edited Photos taken from the wallet of the Accused Containing the
Image of the Private Complainant
Purpose: To prove presence of lewd design attending the acts of the accused
pertaining to the crime as charged.

ISSUE

1. Whether or not the accused committed and is guilty of the crime of Acts of
Lasciviousness

WITNESS

1. Private Complainant, Tara Jane Pot-Pot


Purpose: To testify that the accused committed acts of lasciviousness against her
person by mashing her right breast and that such act was attended by force, threat
and intimidation.

TRIAL DATES

Specifically all Fridays of the month, with the regular appearance of the undersigned City
Prosecutors before this Honorable Court.

RESPECTFULLY SUBMITTED.

Bago City, January 28, 2017.

BAGO CITY PROSECUTORS OFFICE

South Bacolod, By-pass Road, Bago City

By:

SHIELA INUMERABLES

Assistant City Prosecutor

Roll No. 67890 / 5-2-07


IBP. No. 667899 / 12-29-07

MCLE Exempt

PTR Exempt

MARIA REYLAN GARCIA

Assistant City Prosecutor

Roll No. 86754 / 5-2-07

IBP. No. 674539 / 12-29-07

MCLE Exempt

PTR Exempt

JAENISE DE LA PAZ

Assistant City Prosecutor

Roll No. 67890 / 5-2-07

IBP. No. 667899 / 12-29-07

MCLE Exempt

PTR Exempt

Copy Furnished:

BAYAWA, DEL ROSARIO, REYES, SALEM LAW OFFICE

123 Lacson St. Bacolod City, Philippines

Received by: Atty. Anthony Isidro Bayawa IV


Date: 1/30/2017