Republic of the Philippines

REGIONAL TRIAL COURT

__th Judicial Region BRANCH __
_______________________ City

PEOPLE OF THE PHILIPPINES, CRIM. CASE NO.

_______________________

-versus- FOR: VIOLATION OF RA 9262

_______________________,
Accused.
X-----------------------------------------/

PRE-TRIAL BRIEF OF THE ACCUSED

ACCUSED, through the undersigned Counsel, before this Honorable

Court, most respectfully submit this Pre-Trial Brief:

A. SUMMARY OF ADMITTED FACTS AND PROPOSED

STIPULATION OF FACTS

1. The identity, occupation and/or profession, and civil status of

both the private complainant and accused;
2. The fact that accused has regularly provided financial support
in favour of private complainant and their child;
3. The fact that despite the said regular financial support given by
accused, private complainant has filed several complaints
against the former before the Office of the Provincial
Prosecutor of _______________________, Office of the City
Prosecutor of _______________________, PNP Internal
Affairs Service and Regional Investigation Detective
Management Division;
4. The existence and due execution of the following documents
including the contents contained thereof:

a. RESOLUTION (On Preliminary Investigation) dated 28 th

September 2018 by the Office of the Provincial Prosecutor,
Province of _______________________;
b. KASULATAN dated November 2016;
c. Palawan Pawnshop Express Pera Padala Receipts in favour
of private complainant;
 d. MLhuillier Kwarta Padala Receipts in favour of private
complainant;
e. RD Pawnshop Pera Padala Receipts in favour of private
complainant;

B. ISSUES TO BE TRIED

1. Whether or not the fact that accused was only able to deliver
FOUR THOUSAND PESOS ((Php4,000.00) instead of the full
amount of SIX THOUSAND PESOS (Php6,000.00), due to
severe financial constraints, as monthly financial support for the
month of July 2019 ONLY in favour of private complainant
constitutes economic abuse in violation of R. A. 9262; and
2. Whether or not accused is guilty thereof.

C. APPLICABLE LAWS AND JURISPRUDENCE

1. Section 3(a)D of R. A. 9262, otherwise known as An Act

Defining Violence Against Women and their Children,
Providing for Protective Measures for Victims, Prescribing
Penalties Therefore, and for other Purposes; and
2. Act No. 3815 otherwise known as the Revised Penal Code of
the Philippines.

D. DOCUMENTS TO BE PRESENTED

1. RESOLUTION (On Preliminary Investigation) dated 28th

September 2018 by the Office of the Provincial Prosecutor,
Province of _______________________;
2. KASULATAN dated November 2016;
3. Palawan Pawnshop Express Pera Padala Receipts in favour of
private complainant;
4. MLhuillier Kwarta Padala Receipts in favour of private
complainant;
5. RD Pawnshop Pera Padala Receipts in favour of private
complainant;
6. Counter-Affidavit of the Accused; and
7. At least two (2) reserved documents.

E. NAMES OF WITNESSES
 1. _______________________; and
2. At least two (2) reserved documents..

F. AVAILABLE TRIAL DATES

Specifically all Fridays of the month, with the regular appearance of

the undersigned counsel before this Honorable Court.

RESPECTFULLY SUBMITTED, February 7, 2020,

_______________________, _______________________, Philippines,

ATTY. _______________________
Counsel for the Accused

Copy furnished: