REPUBLIC OF THE PHILIPPINESMUNICIPAL TRIAL COURTSAN FERNANDO, CEBU

PEOPLE OF THE PHILIPPINESPlaintiff,CRIM CASE NO. 3622-versus- FOR : VIOLATION OF R.A10586 (ANTI-DRUNK ANDDRIVING ACT OF 2013)

FERNANDO ALFECHE LOGUIBERAccused.

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PRE-TRIAL BRIEF OF THE ACCUSED

ACCUSED, through the undersigned counsel, before this Honorable Court, most respectfully submit this Pre-Trial Brief :

STIPULATION OF FACTSThe defense will only stipulate as to the jurisdiction of this court and the identity of the accused.

EVIDENCE FOR MARKING1. Affidavit of the accused Fernando Alfeche LoguiberPurpose : To prove the fact that the accused was not driving under the influence of liquor.2. Joint Affidavit of Arresting Officers P02 Cleofas Cabrera Jr., and P02 Edgar Enclonar Purpose : To prove the fact that the arresting officers arrested the accused without conducting any field sobriety test required under R.A 10586.

ISSUES Whether or not tha accused is guilty of R.A 10586.WITNESSESS :

1. Accused Fernando Loguiber to testify on the fact that he is not driving under the influence of liquor.

TRIAL DATES

At the convenience of this Honorable Court.