REPUBLIC OF THE PHILIPPINES

COURT OF APPEALS
MANILA

PEOPLE OF THE PHILIPPINES,

Plaintiff,
- versus -

CRIMINAL CASE NO.0012345

FOR: MURDER

MARK VILLEGAS AND MARTIN,

VILLEGAS,
Accused.
x-----------------------------------------------x

PRE-TRIAL BRIEF
ACCUSED, through the undersigned counsel, before this Honorable
Court, most respectfully submit this Pre-Trial Brief:

BRIEF STATEMENT OF THE CASE

The complaint was filed against the herein accused, Martin Villegas and
Mark Villegas for the case of Murder of Dempsy. The case happened on
Setember 24, 204 in San Ruiz Village Makati City.

A. BRIEF STATEMENT OF THE CASE

In it Complaint dated October 1, 2014, The people of the Philippines
filed a case of Murder of Dempsey against the herein accused Mark and
Martin Villegas. People of the Philippines presented the following evidence
against the accused; 2 ski masks and 2 baseball bats with dried blood stains.
In the decision dated October 15, 2014 The Regional Trial Court found the
herein accused guilty of the filed offense.

B. WITNESSES FOR THE ACCUSED

1. Tano, Caretaker of the house of the accused
2. Aling Maria, neighbor in the subdivision where the evidence was
found

C. EVIDENCE FOR MARKINGS

1.
2.
3.
4.

Skii Mask A
Skii Mask B
Baseball Bat A
Baseball Bat B

D. ADMISSION OF FACTS
The accused admit the following:
1.
The identities of those charged in the information and that of the
persons arraigned are one and the same;
2.
the identity of Sulpicio Treyes, the victim;

E. APPLICABLE LAWS AND JURISPRUDENCE

1.
2.
3.
4.

Section 3 of Rule 128 of the Rules of Court

Article III Section 3 Paragraph 2
Article III Section 2 of the 1987 Constitution
RULE 126 - SEARCH AND SEIZURE

F. ISSUES TO BE RESOLVED
1. Whether or not the accused committed the crime charged;
2. Whether or not the evidence presented by the plaintiff can be used
against the accused

RESPECTFULLY SUBMITTED.
Makati City, Metro Manila, Philippines, October 24, 2014

AIMEE BERNADETTE B. QUINONES

Public Attorneys Office
Counsel for Accused-Appellant
Roll of Attorney 1234
MCLE Compliance Certificate II; 1-24-14
IBP 21345; 1-24-14; City of Manila
PTR 123465; 1-25-14; City of Manila

Copy furnished:
Atty. Reggie Landrito
Solicitor General
Roll of Attorney 12345
MCLE Compliance Certificate II; 7-19-14
IBP 21345; 1-14-14; City of Manila
PTR 123465; 1-20-14; City of Manila