Republic of the PhilippinesREGIONAL TRIAL COURT

National Capital Judicial RegionManila, Branch 1

PEOPLE OF THE PHILIPPINES, Plaintiff,

-vs.- Criminal Case No. 14344For: Bigamy

JERICHO ROSALES, Accused.

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PRE-TRIAL BRIEF FOR THE ACCUSED

Comes Now, the accused Jericho Rosales, by counsel and unto this Honorable Court, respectfully submits its pre-trial brief alleging among others:

I. Brief Statement of the Case

The herein plaintiff, Maja Salvador, filed a criminal complaint for Bigamyagainst the accused, Jericho Rosales, alleging that the accused has been legally married to Angel Locsin on August 27, 1998 in a civil wedding ceremony solemnized by Hon. Alfredo Lim, then City Mayor of Manila. Plaintiff further claimed that the accused contracted a subsequent marriage with her on May 1, 2013 in Paco Church, Manila without the first marriage being legally dissolved.

As alleged and argued in the Counter-Affidavit of the accused dated May 5, 2014, accused Jericho Rosales interposed the following defenses:

1. That no marriage ceremony at all was performed by a duly authorized solemnizing officer. Jericho Rosales and Angel Locsin merely signed a marriage contract on their own on August 27, 1998;

2. That the judicial proceedings be suspended on the ground that the civil case for judicial nullification of his marriage with Angel Locsin posed a prejudicial question in the bigamy case;

II. Statement of the Issue

The issue here to be resolved is whether or not the accused committed the crime of bigamy.

III. Applicable Laws and Jurisprudence

1. Supreme Court Decisions2. New Civil Code

3. Revised Penal Code

IV. Witnesses to be presented1. Jericho Rosales, accused, to testify on the …2.Mrs. Didith Reyes, former secretary of former Mayor Alfredo Muslim, to testify on…3.Mr. Mark Gil, landlord, to testify on the…

V. Documentary Evidences1. Exhibit A – 2. Exhibit B -3. Exhibit C –

VI. Available Trial DatesMay 10, 15, 17, 2014

VII. Additional witnesses and other documentary evidence whose names are not listed or not yet available as of this date, are hereby reserved for presentation and proper identification during the scheduled hearings.

Manila, Philippines, May 8, 2014.

JERICHO ROSALESBY:

ATTY. RENALYN S. SANTIAGO

Counsel for the Accused123 Malate, ManilaIBP No. 54321 dated 03-26-2012

COPY FURNISHED: IVY CATIPONCity ProsecutorManilaRegistered Mail No. 12345

Republic of the PhilippinesREGIONAL TRIAL COURT

National Capital Judicial RegionManila, Branch 1

THE PEOPLE OF THE PHILIPPINES, Plaintiff,

-vs.- Criminal Case No. 14344For: Bigamy

JERICHO ROSALES, Accused.

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INFORMATION 

The undersigned City Prosecutor accuses JERICHO ROSALES of the crime of BIGAMY, committed as follows:

That on or about August 27, 1998, in the City of Manila, Philippines, the above-named accused, JERICHO ROSALES, being then legally married to ANGEL LOCSIN and without such marriage having been legally dissolved, did then and there willfully, unlawfully and feloniously contract a second or subsequent marriage with MAJA SALVADOR.

 CONTRARY TO LAW 

  IVY CATIPON City Prosecutor

This is to certify that a preliminary investigation has been conducted in the above-entitled case, wherein the accused was given a chance to appear and that on the basis of the evidence presented, there is reasonable ground to believe that the offense charged has been committed and the accused is probable guilty thereof.

Manila, Philippines, May 7, 2014.

CHARM ITABLE City Prosecutor

WITNESSES:NAMES ADDRESS__________________ _________________________________________________ _______________________________

BAIL RECOMMENDED: PHP ___________