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.
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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