(Sample)

Republic of the Philippines

Department of Finance
BUREAU OF LOCAL GOVERNMENT FINANCE
Cordillera Administrative Region
Baguio City

Mr. JUAN P. DELA CRUZ BLGF Admin. Case No. 2017-001

Municipal Treasurer of __________ For: Dishonesty and Grave Misconduct
Province of ___________________
Respondent.
x---------------------------------------------x

PRE-HEARING BRIEF

Prosecutor/Designated Prosecutor, respectfully submits his Pre-Hearing Brief, as

follows:

I. BRIEF STATEMENT OF PLAINTIFF'S CLAIMS:

Mr. Juan Dela Cruz was issued a government vehicle since August 10, 1997 and he
did not transfer the vehicle to any of his staff. Notwithstanding this fact and the said
memorandum, he received transportation allowance particularly for the months of April
and September 1998.

Despite the regular receipt of Mr. Juan Dela Cruz of his monthly Representation and
Transportation Allowance (RATA) in the amount of P4,000.00, he still prioritizes himself
in the use of the office vehicle (Tamaraw FX) in spite of the directive from the Central
Office that he cannot use the service vehicle for official purposes and at the same time
receive his transportation allowance.

The Respondent did not comply with the directive of the Central Office addressed to
all Regional Human Rights Directors, as follows: ‘to regularize your receipt of the
transportation allowance component of the RATA to which you are entitled monthly, you
are hereby directed to immediately transfer to any of your staff, preferably one of your
lawyers, the memorandum receipt of the vehicle(s) now still in your name;’

Respondent certified in his monthly liquidation of his RATA that he did not use any
government vehicle for the corresponding month, which is not true because he is the
regular user of the government vehicle issued to BLGF-CAR.

II. ISSUE/S TO BE TRIED:

Whether the Respondent is guilty as charged.

III. EVIDENCE

(The documents or exhibits to be presented, stating the purpose thereof)

(The number and names of the witnesses)

1. DOCUMENTARY EXHIBITS:
 1.1. BLGF-Central office Memorandum dated February 27, 1998 for the
purpose of proving that the same was violated by the Respondent;

1.2. RATA Monthly Liquidation to prove that Respondent certified that he

did not use any government vehicle for the corresponding month, which is
not true because he is the regular user of the government vehicle.

1.3. Judicial Affidavit of the Witnesses to be taken as their direct testimony

to corroborate the fact of Respondent’s denial of the use of the
government vehicle by the other staffs and personnels of the office for the
reason that Respondent will use it.

2. LIST OF WITNESSES:

1. Brigette Alban to prove the matter of dishonesty of the Respondent;

2. Atty. Lin Macario to corroborate the testimony of Brigette Alban;
3. Mr. Diane Salva, disbursing officer to attest that RATA was released during the
month of April and September;

IV. AVAILABLE TRIAL DATES

November 10, 2017, November 13, 2017, November 15, 2017 and November 20,
2017.

RESPECTFULLY SUBMITTED.

Baguio City. 08 November 2017.

FRANCISCO CRUZ
Counsel for the Plaintiff
2nd Floor ADM Bldg., Mabini Street
Baguio City, Philippines

By:

JOE D. FRANCISCO
IBP # 605482 1/8/11
PTR # 0417576 1/8/11 Baguio City
ROA 30724
MCLE Compliance No. II 01-23455

Copy Furnished:
By Personal Service

Atty. Maria Cardo

Cardo Law Offices
10 Campo Filipino, Naguilian Rd., Baguio City