Pre Trial Brief - PROSECUTOR

Republic of the Philippines
REGIONAL TRIAL COURT

ILOCOS NORTE
FIRST JUDICIAL REGION
Branch 8. Laoag City

PEOPLE OF THE PHILIPPINES,
Plaintiff,
versus Criminal Case No. 14344

FOR: Section 5 (a), 5 (e), 5(i) of R.A 9262 or
The Anti-
Violence Against Women and their
Children Act
NASH CONTIS ABRENICA,
Accused.
x----------------------------------------------x
PRE-TRIAL BRIEF
Private complainant Mich Padilla-Abrenica, by counsel, most respectfully states

that:
I. BRIEF STATEMENT OF FACTS AND THE CASE
This is a criminal case filed by private offended party against the above-named accused
for Section 5(a), 5(e), 5(i) of Republic Act 9262 or otherwise known as the Anti-
Violence against Women and their Children Act. Accused and Complainant were married
for 25 years. They were blessed with 3 children aged 24, 22 and 15. On many
occasions, complainant suffered physical violence from the accused. The most recent
was that of October 17, 2021 where complainant suffered bruises in her chest, neck,
right arm and shoulder as well as stitches on her left brow. Accused also threatened to
stop financially supporting the complainant and their children. Further, Accused was
having an extra-marital affair with a bank manager while his marriage with the
complainant is still subsisting. These circumstances caused physical, mental and
emotional suffering to the complainant and their children. All the elements of Republic
Act 9262 or otherwise known as the Anti-Violence against Women and their Children
Act are evident from Accused ABRENICA’s actions, to wit: 1. The offended party is a
woman and/or her child or children; 2. The woman is either the wife or former wife of
the offender, or is a woman with whom the offender has or had a sexual or dating
relationship, or is a woman with whom such offender has a common child. As for the
woman's child or children, they may be legitimate or illegitimate, or living within or
without the family abode; 3. The offender causes on the woman and/or child mental or
emotional anguish; and 4. The anguish is caused through acts of public ridicule or
humiliation, repeated verbal and emotional abuse, denial of financial support or custody
of minor children or access to the children or similar such acts or omissions.
II. PROPOSED STIPULATION OF FACTS
2.1 The identity of the accused Nash Contis Abrenica
2.2 The jurisdiction of Honorable Court over the subject matter and person of the
accused.
2.3 Complainant Mich Padilla-Abrenica and accused Nash Contis Abrenica were
married for 25 years. (Exhibit “A”)
2.4 Complainant Mich Padilla-Abrenica and accused Nash Contis Abrenica had three
children together.
(Exhibit “B”)
2.5 Accused Nash Contis Abrenica pushed complainant Mich Padilla-Abrenica, which
caused the latter to fall 5 steps downward the stairs and sustained injuries on the night
of October 17, 2021. (Exhibit “”)
2.6 Accused Nash Contis Abrenica admitted to having an affair with a bank manager.
(Exhibit “”)
2.7 Accused Nash Contis Abrenica threatened to stop his financial support to the
complainant and their children. (Exhibit “”)
2.8 Accused Nash Contis Abrenica is a business man who owns a multi-million
company. (Exhibit “D”)
III. ISSUE
3.1 Whether accused Nash Contis Abrenica committed the alleged acts in such
manner and circumstances as to constitute a violation for Section 5(a), 5(e), 5(i) of
Republic Act 9262 or otherwise known as the Anti-Violence against Women and their
Children Act.
IV. EVIDENCE
4.1 Documentary Exhibits
EXHIBIT
Marriage Certificate A
Birth Certificate of the three children B
Mich Padilla-Abrenica’s Medical Record C
Nash Contis Abrenica’s Business Records D
Judicial Affidavit – Dorothy Padilla E
Judicial Affidavit – Yaya Maine F
Judicial Affidavit – Son JM G
4.2 Object Evidence
EXHIBIT
Cctv footage inside the house A
Text conversations of Nash and his paramour B
Bills Payment C
Children School Fees D
Mich Padilla Abrenica’s Pictures of Bruises and E
Cuts
Video threatening to stop financial support F
2. Witnesses
a. Yaya Maine
b. Mr. JM Abrenica
c. Mrs. Dorothy Padilla
4.3 Private complainant reserves the right to present additional, rebuttal, and sur-
rebuttal documentary and testimonial evidence in the course of the trial, if necessary.
V. POSSIBILITY OF AMICABLE SETTLEMENT
5.1 Private offended party is willing to amicably settle the civil aspect of the case
provided such settlement is fair and reasonable under the circumstances, and for such
purpose, to submit the case to alternative dispute resolution.
VI. AVAILABLE TRIAL DATES
6.1 Counsel for the private complainant proposes the following dates for the trial of
this case: xxx, xxx, xxx, xxx, xxx, xxx, or on such dates as may be convenient to the
calendar of the Honorable Court and subject to the availability of the other party.
MOST RESPECTFULLY SUBMITTED.
Laoag City, November 03, 2021.
ATTY. CHON A. BELLS

City Prosecutor’s Office
Laoag City
(074) 442-6331
[email protected]
Roll No. 67890
MCLE V No. 0010987/10-8-2021
IBP No. 023789/1-10-2022/ Laoag City
PTR No. 7129677/1-5-2022/ Laoag City
COPY FURNISHED:
NASH CONTIS ABRENICA

#85 Pacific Building, Padre Gomez St.,
Brgy. 16, Laoag City

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Republic of the Philippines

REGIONAL TRIAL COURT

versus Criminal Case No. 14344

NASH CONTIS ABRENICA,

Private complainant Mich Padilla-Abrenica, by counsel, most respectfully states

I. BRIEF STATEMENT OF FACTS AND THE CASE

II. PROPOSED STIPULATION OF FACTS

2.1 The identity of the accused Nash Contis Abrenica

4.1 Documentary Exhibits

4.2 Object Evidence

VI. AVAILABLE TRIAL DATES

MOST RESPECTFULLY SUBMITTED.

Laoag City, November 03, 2021.

ATTY. CHON A. BELLS

NASH CONTIS ABRENICA

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