REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

NATIONAL CAPITAL JUDICIAL REGION
MANILA CITY, BRANCH 101

PEOPLE OF THE PHILIPPINES,

Complainant,
Criminal Case No. 08-001
For: Qualified Theft
(Violations of Article 310, in
relation to
Article 308, of the Revised Penal Code)
-versus-

MACON BANGALAN,
Respondent.

PRE-TRIAL BRIEF OF THE DEFENSE

MACON BANGALAN, 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 admitted facts:

1. That Macon Bangalan is presently employed as Cashier of PUP-

COL Employees Savings and Loans Association, Inc. (PCESLAI).
The Company is a corporation duly organized and existing under and
by virtue of the laws of the Republic of the Philippines, and engaged
in the business of lending loans and other assistance to its members,
with principal place of business at G/F NALLRC Bldg. PUP A.
Mabini Campus, Anonas St., Sta. Mesa, Manila ;

2. That Complainant KAKIT LAW, is of legal age, Filipino, with office

address at G/F NALLRC Bldg. PUP A. Mabini Campus, Anonas St.,
Sta. Mesa, Manila presently employed as President of PUP-COL
Employees Savings and Loans Association, Inc. (PCESLAI);

3. That ALLEN BAUTISTA is the Vice President for Finance of

PCESLAI who is a superior officer of Ms. Macon Bangalan;

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 4. That the guard on duty last May 30, 2017 was Mr. EDUARDO
REYES ;

5. That Duday de Vera is employed as Marketing Manager of PUP-COL

EMPLOYEES SAVINGS and LOANS ASSOCIATION, INC
(PCESLAI);

6. That Ms. Bangalan is not a College degree holder;

7. That there is a pending case against MR. ALLEN BAUTISTA for

the threats he made against Macon Bangalan;

EVIDENCE FOR MARKING

Exhibit Description Purpose

1 Screen capture images To prove threat and lack
of Mr. Allen Bautistas of intent to gain and
text messages voluntariness on the
part of the accused
2 Affidavit of Eduard To prove threat and lack
Reyes, security guard of intent to gain and
voluntariness on the
part of the accused
3 Affidavit of Duday de To corroborate the
Vera testimony of Eduard
Reyes and the Accused
4 Deposit Receipt To prove that the
amount withdrawn was
not appropriated by the
accused for his own
benefit but was
transferred to Allen
Bautista
5 Information of Grave To prove that a case of
Threats Against Allen grave threat was filed
Bautista by accused involving
the same transactions
and occurrences

ISSUES
Whether or not the accused is guilty Qualified Theft (Violations of Article
310, in relation to Article 308, of the Revised Penal Code)
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 WITNESSES

1. Macon Bangalan
2. Eduard Reyes
3. Duday de Vera

TRIAL DATES

Specifically all Fridays of the month, with the regular appearance of

the undersigned city prosecutors before this Honorable Court.

RESPECTFULLY SUBMITTED.

Manila, Philippines; August 17, 2017.

By:
PUBLIC ATTORNEYS OFFICE
Department of Justice
DISTRICT OFFICE

By:

ATTY. YEYEN EVORA

Public Attorney Roll
No. IBP
No.
MCLE Comp. No. III-

Copy furnished through personal service:

Atty. __________________
Counsel for the Accused
Quezon City
Date: ____________
Time: ____________
Atty. __________________
Counsel for the Accused
Quezon City
Date: ____________
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Time: ____________

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