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Pre - Trial

This document is a pre-trial brief submitted by the defense counsel for an accused named Samuel Dal-Ing Guyon who is charged with violation of PD 705. The brief discusses that the accused does not wish to engage in plea bargaining and maintains his innocence, proposes stipulations of facts, identifies the issue to be tried, and lists four witness who will testify in defense of the accused.

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Presley John Namingit
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42 views2 pages

Pre - Trial

This document is a pre-trial brief submitted by the defense counsel for an accused named Samuel Dal-Ing Guyon who is charged with violation of PD 705. The brief discusses that the accused does not wish to engage in plea bargaining and maintains his innocence, proposes stipulations of facts, identifies the issue to be tried, and lists four witness who will testify in defense of the accused.

Uploaded by

Presley John Namingit
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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Republic of the Philippines

REGIONAL TRIAL COURT


Second Judicial Region
Branch 14
Lagawe, Ifugao

People of the Philippines, CRIM. CASE NO. 3180


Plaintiff,
-versus- FOR:
VIOLATION OF PD 705

SAMUEL DAL-ING GUYON,


Accused.
X-------------------- ---x
PRE – TRIAL BRIEF
(FOR ACCUSED)

WITH UTMOST RESPECT TO THE HONORABLE COURT,


accused, through the undersigned counsel, most respectfully submits his Pre-Trial
Brief.

POSSIBILITY OF PLEA BARGAINING

The accused is not willing to plea bargain as he maintains his innocence of


the crime charged.

PROPOSED STIPULATION OF FACTS

1. Wilson T. Masi and Jennifer Bayanes never met Samuel Guyon prior to the
joint meeting with the CENRO personnel.
2. The alleged cutting of trees was referred to CENRO – Lamut, Ifugao against
Lita Kitungan.
ISSUE TO BE TRIED

Whether or not the accused is guilty as charged.

EVIDENCE FOR MARKING

None.

WITNESSESS

1. Samuel D. Guyon to deny the accusations against him.


2. La-kay Pihet to testify that he is staying on the adjacent lot where the alleged
trees were cut and he never saw Samuel Guyon on the area cutting trees.

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3. Charles Dilit to testify that he is cultivating the adjacent area where the
alleged trees were cut and that the area was already cleaned before January
2021; He never saw Wilson T. Masi and Jennifer Bayanes visit the area in
January and February 2021;
4. Angelito Alhido that he witnessed the cleaning of the area by some
individuals on December 2020 and he never saw Samuel Guyon on the said
lot.

RESPECTFULLY SUBMITTED this 25th day of April 2022 at Lagawe,


Ifugao, Philippines.

NAMINGIT LAW OFFICE


2 nd
Floor, Alfredoracion Building
Pob. East, Lagawe, Ifugao

By:

ATTY. PRESLEY JOHN L. NAMINGIT


Counsel for Accused
Roll No. 69260 – May 31, 2017
IBP No. 168595 – Dec. 27, 2021
PTR No. 4205501 – Dec. 29, 2021
MCLE Compliance No. VI-0013828

Copy Furnished:

PROS. PETRONILO M. DUBADEB


Provincial Prosecutor’s Office
Lagawe, Ifugao

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