Republic of the Philippines
7th Judicial Region
                                             REGIONAL TRIAL COURT
                                                     BRANCH 2
                                              Tagbilaran City, Bohol
 THE PEOPLE OF THE PHILIPPINES
 Plaintiff,                                               Criminal Case No. 25157-25159
           -versus-
                                                          For:
 CHARESMA PENARANDA Y DASPUEBLOS                          SECTION 5 AND 11, R.A. 9165
 Accused.
 X - - - - - - - - - - - - - - - - - - - - - - -/
                                       PRE-TRIAL BRIEF FOR THE ACCUSED
        ACCUSED through herein undersigned counsel, in the above-entitled case, and to the Honorable
Court, most respectfully submits his Pre-Trial Brief, and state:
    I.         BRIEF STATEMENT OF THE ACCUSED
                   Accused vehemently denies the allegations in the informations charging him for the
               crimes;
                  SHE DID NOT SELL NOT POSSESS ILLEGAL NARCOTICS AS ALLEGED IN THE
               INFORMATION. SHE DENIES ALL ALLEGATIONS IN THE INFORMATIONS. SHE AND HER
               BOYFRIEND WERE JUST FORCED INTO A RED VEHICLE AND ON SEPTEMBER 2, 2022 AND
               THEY WERE FORCED TO PARTICIPATE IN A SIMULATED DRUG INVENTORY TO MAKE THEM
               APPEAR AS THE SUBJECT OF THE SAID OPERATION
    II.        POSSIBILITY OF AMICABLE SETTLEMENT
                   The accused is very amenable to the possibility of an amicable settlement.
    III.       STIPULATION/ADMISSION OF FACTS
                   None.
    IV.        PROPOSED STIPULATION OF FACTS
                   None
    V.         THE ISSUES TO BE TRIED OR RESOLVED
              Whether or not Accused is guilty beyond reasonable doubt of the crimes above-mentioned.
    VI.        NUMBER AND NAMES OF WITNESS TO BE PRESENTED
           1. Accused Charesma D. Penaranda
               -To refute all the allegations in the complaint.
           2. Co-accused Cyril Jon Pamaong
               -   To support the cause of the accused
    VII.       DOCUMENTS OR EXHIBITS TO BE PRESENTED
          Defendant reserves the right to present additional documentary or object evidence in the
course of the trial, if necessary.
    VIII.      APPLICABLE LAWS AND JURISPRUDENCE
           1. Revised Penal Code
           2. Applicable jurisprudence established by the Supreme Court
           3. R.A. 9165
 IX. AVAILABLE TRIAL DATES
           Herein Accused will abide by the calendar of the Honorable Court.
           Respectfully submitted.
           City of Tagbilaran, this November 25, 2022.
                                         PUBLIC ATTORNEY’S OFFICE
                                         Tagbilaran City District Office
                                        Hall of Justice, New Capitol Site
                                                 Tagbilaran City
                                                      By:
                                           MICHAEL JORDAN M. TUBAL
                                                Public Attorney I
                                                 Roll No. 75791
                             IBP O.R. No. 190705 PTR No. 2467440-Bohol-01/11/2022
                                 MCLE Compliance No. VII- 0010126- 02/15/2022
Personal Delivery
TAGBILARAN CITY PROSECUTION OFFICE
Pros. Jonel Torregosa