REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
NATIONAL PROSECUTION SERVICE
OFFICE OF THE CITY PROSECUTOR
QUEZON CITY

THE PEOPLE OF THE PHILIPPINES,

Complainant,
-vs-

I. S. No. 9987
For: Bigamy (Art. 349,
Revised Penal Code)

NEIL IAN RAMOS,

Respondent.
X----------------------------------------------------------X

PRE-TRIAL BRIEF OF THE PROSECUTION

THE PEOPLE OF THE PHILIPPINES, through the undersigned City

Prosecutor, respectfully submits to this Honorable Court this Pre-Trial Brief to
wit:

I.
PROPOSED STIPULATION OF FACTS
The accused proposes the following facts:
1. That the respondent Neil Ian Ramos and I met sometime in January
2011 while being schoolmates in college at University of the
Philippines and became sweethearts after a short courtship.
2. As we were both too much in love, we hastily got married on
November 25, 2011 in a civil wedding ceremony solemnized by the
Mayor of Quezon City.
3. After our wedding, we lived together as husband and wife in our
conjugal dwelling in Matalino St., Quezon City.
4. Several months into our marriage, respondent began to exhibit his
no caring attitude. He would leave the house without prior notice
and would come back only very late at night. Such behaviour on the
part of respondent resulted in out quarrels and verbal altercations.
5. Sometime in June 2013, we had a violent quarrel because at that
day, he did not come home and only appear after 5 days without
any explanation.
6. I asked him for his explanation, but he suddenly got mad and yelled
at me, saying that I have no right to ask him where will he go and
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when will he come home. After our quarrel, he left our conjugal
dwelling and this was the last time I ever saw him. Since then, I had
not seen, communicated nor heard anything from him or about his
whereabouts. So I returned to my parents abode at Sampaloc,
Manila and stayed there for about two months.
7. To cope with the sudden turn of event in my life, I went abroad to
California, U.S.A., on September 9, 2013 to unwind and for
employment purposes as well, and came home after almost two (2)
years.
8. Sometime in October 2015, a relative who works in the Quezon City
Registrars Office informed me that my husband, respondent Neil
Ian Ramos has gotten married to another woman, a certain Rica
Jane Angeles, in a religious ceremony solemnized by Fr. Christian
Gomez at the St. Peter Parish Church in Quezon City, on February
18, 2015.
9. My marriage with respondent Neil Ian Ramos is still subsisting and
has not been annulled or dissolved. His act of contracting a second
marriage to Rica Jane Angeles despite the subsistence of our
marriage constitutes the crime of bigamy punishable under Article
349 of the Revised Penal Code.
II.
ISSUES TO BE TRIED
Whether or not the Respondent committed the crime charged.

III.
EVIDENCE FOR MARKING
The petitioner will present the following documents.
1. Marriage Certificate between Theresa Santos-Ramos and Neil Ian
Ramos made on 25 November 2011.
2. Marriage Certificate between Rica Jane Angeles and Neil Ian Ramos
made on 18 February 2015.

IV.
WITNESSES TO BE PRESENTED
The Petitioner will present the following witnesses:
1. The complainant for purposes of proving her existing marriage with
the accused
2. Other witnesses as may be determined to be relevant to the case
during the course of trial.

V.
AVAILABLE DATES FOR TRIAL
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The Petitioner respectfully requests that the trial dates be agreed upon
in open court at such dates and time convenient to the parties and the
calendar of this Honorable Court.
WHEREFORE, premises considered, it is respectfully prayed unto this
Honorable Court that the foregoing Pre-Trial Brief be duly noted.
Quezon City, 07 September 2016.

QUEZON CITY PROSECUTORS OFFICE

4th Floor, Hall of Justice, Mayaman Street,
Quezon City, 1101 Metro Manila

By:

ATTY. Marilyn Lopez

Assistant City Prosecutor
IBP No. 534585; 02/10/2013- Quezon City
PTR No. 64936; 02/10/2013- Quezon City
Roll No. 061793; 03/17/2010
MCLE No. 5-321; 05/15/13

Copy furnished:

ATTY. Gohol
Counsel for the Defense
Address

Receive by: ____________

Date: ________________

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