REPUBLIC OF THE PHILIPPINES

6TH JUDICIAL REGION

BRANCH_____
PROVINCE OF ILOILO
ILOILO CITY

PEOPLE OF THE PHILIPPINES Criminal Case No. 18-004

Plaintiff,

- versus - FOR: Violation of Section 5 (b),

Article III of RA 7610

NOELITO P. TONTORO,
Accused.
x-------------------------------------------x

PRE-TRIAL BRIEF OF THE ACCUSED

ACCUSED, through the undersigned Counsel, before this Honorable

Court, most respectfully submits this Pre-Trial Brief:

SUMMARY OF ADMITTED FACTS AND PROPOSED STIPULATION OF

FACTS

The following are the proposed facts:

1. The identity of NOELITO TONTORO as the accused in this case;
2. The identity of PEARL GASADOR, the victim;
3. That the accused and victim knew each other;
4. That the accused and victim are sweethearts;
5. That since the accused and victim are sweethearts, the usual
intimacies between the two i.e. kissing, cuddling and even sexual
intercourse is normal and consented;
6. That the victim agreed voluntarily to take the accused as her lover;
7. That the victim voluntarily and willingly, on her own volition, followed
the accused to Queen’s Court Lodge, Mandurriao, Iloilo City on
November 10, 2017.
8. That the victim voluntarily and willingly engaged in a sexual
intercourse with the victim during the course of their relationship;

EVIDENCE FOR MARKINGS

1. Judicial Affidavit of the accused Noelito P. Tontoro:

Purpose: To prove that there exists a mutual relationship of love and
understanding between the accused and the victim; and that the sexual acts
werecommitted willingly clothed with full understanding and consent between
both parties.
2. Judicial Affidavit of Charrie C. Ursua:
Purpose: To prove that the said relationship between the accused; and the
victim exists and is not held in secrecy as it is fully known by their friends and
colleagues.
3. Photographs of Pearl Gasador and Noelito Tontoro:
Purpose: To further support the claim that the victim is the lover of the
accused; and that she was not threatened in any way in order to engage in
such relationship with said accused.
4. Photographs of the messages exchanged by the accused and the
victim:
Purpose: To prove that the victim and the accused shared mutual feelings
toward each other and would communicate by exchanging feelings of love and
affection.

ISSUES

1. Whether or not the accused is guilty of the crime charged.

WITNESSES

1. NOELITO TONTORO, to testify as to his alleged relationship with the

victim and as to the corresponding sexual relations with the victim.
2. CHARRIE URSUA, to testify that the relationship between the victim
and the accused is publicly known to friends and colleagues.

TRIAL DATES

Specifically all Fridays of the month, with regular appearances of

undersigned city prosecutors before this Honorable Court.

RESPECTFULLY SUBMITTED.
Iloilo City, Iloilo Philippines, JuLY 21, 2018.

ABS LAW OFFICE

EDT Bldg., Jaro, Iloilo City

By:

ATTY. DAPHNE JADE E. PANES

Counsel for the Defense
Roll of Attorney No. 101515
PTR No. 121314/Lifetime/Iloilo City
IBP No. 121314/0-15-17 /Iloilo City
MCLE Compliance No. III-000-1510

ATTY. KRISNA YASAY SOLIS

Counsel for the Defense
Roll of Attorney No. 111111
PTR No. 09876/Lifetime/Iloilo City
IBP No. 8656495/0-15-17 /Iloilo City
MCLE Compliance No. III-000-1015
Copy Furnished:

PROS. JED SALVIO PARACHA

Assistant City Prosecutor
Ramon Q. Avancena Hall of Justice
Bonifacio Drive, Iloilo City

Received by: __________________

Date:_________________________