Republic of the Philippines

Fourth Judicial Region

REGIONAL TRIAL COURT
Branch ___
Puerto Princesa City
PEOPLE OF THE PHILIPPINES, CRIMINAL CASE NO. _____
plaintiff,
-versus- FOR:
RAMIR MANLAVI Y PARCON alias DUDAY, MURDER
accused.
x------------------------------------------------------x
PRE TRIAL BRIEF OF THE ACCUSED
THE ACCUSED, through the undersigned Counsel, before this Honorable Court, most
respectfully submits this Pre-Trial Brief:
SUMMARY OF ADMITTED FACTS
AND PROPOSED STIPULATION OF FACTS
The following are the proposed stipulation of facts:
1. The identity of the deceased, in the person of Zues Tolentino Zenarosa.
2. The identity of the accused.
3. The death of the victim, Zues Tolentino Zenaroza.
4. That the date, place and time of the killing, which was 31 October 2013 at about 8:20 in
the evening at Purok Sandiwa, Bgy. Tiniguiban, Puerto Princesa City.
STIPULATION OF FACTS

EVIDENCE FOR MARKING
1. Affidavit of Ramil P. Manlavi
Purpose: To prove that he did not wilfully, unlawfully and feloniously assault, attack and
strike or hit Zues Zenarosa.
2. Affidavit of Tirzo Arzaga
Purpose: To corroborate the testimony of the accused in proving that there was no
intentional willingly committed by the accused.
3. Affidavit of Jobelle Quimay
Purpose: To prove that Zues Zenarosa has a knife and ran after the accused and
accidentally fell and hit the head in a large stone.
4. Medical Certificate of the accused
Purpose: To prove that the accused was physically beaten by the deceased.
ISSUES
1. Whether the accused committed the crime charged.
2. Whether or not the accused is guilty of committing the crime;
3. Whether or not the victim death is caused by the stumbling or falling of the victim.
WITNESSESS
1. Ramir P. Manlavi to testify that there was no wilful and felonious killing and that the
death of the deceased was due to accident, independent of the accused.

2. Jobelle Quimay to collaborate the testimony of the accused, that he heard the infliction of
physical biting of the deceased and his companies upon the person of the accused, that
Zues ran after the accused with threats of killing him and the accidental falling and
hitting of the accused head upon a large stone that caused his death.

3. Tirzo Arzaga also to collaborate the testimony of the accused, that he heard the infliction
of physical biting of the deceased and his companies upon the person of the accused, that
Zues ran after the accused with threats of killing him and the accidental falling and
hitting of the accused head upon a large stone that caused his death.

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

RESPECTFULLY SUBMITTED
Puerto Princesa City, 11 October 2014


POSTRE, RABANG AND MALATAG
LAW OFFICE
Room 100, Petal Building
Manalo St.,
Puerto Princesa City.

By:

CATHERINE MAE POSTRE
Counsel for the Defense
Roll No. 829388 / 01-09-2011
IBP No. 287367 / 03-20-2011
MCLE Compliance No. 183762 / 08-2-2011
PTR No. 273837/ 12-28-2011

and

APRIL JOY RABANG
Counsel for the Defense
Roll No. 128374 / 09-01-2010
IBP No. 283984 / 10-20-2010
MCLE Compliance No. 287364 / 12-2-2010
PTR No. 273837/ 12-29-2010
Copy Furnished:
PROS. IRA DELA ROSA
PROS. HAZIELL PASCUA
PROS. DEVIEANN MAE LAMBAN
City Prosecutors
City of Puerto Princesa