REPUBLIC OF THE PHILIPPINES

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

THE PEOPLE OF THE PHILIPPINES,

Complainant,
-vs- I. S. No. 9987
For: Bigamy (Art. 349,
Revised Penal Code)
TIMOTHY A. LIM,
Respondent.
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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.
POSSIBILITY OF AMICABLE SETTLEMENT OR
ALTERNATIVE MODES OF DISPUTE RESOLUTION

The Petitioner is not willing to consider any amicable settlement or undergo

alternative modes of dispute respect to primary petition. However, the Petitioner is open
for the possibility of amicable settlement in relation to the partition and accounting of the
absolute community of properties and assets of her union with the Respondent.

II.
PROPOSED STIPULATION OF FACTS
The accused proposes the following facts:
1. That the respondent Timothy A. Lim 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.

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 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 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.

III.
ISSUES TO BE TRIED
Whether or not the Respondent committed the crime charged.

IV.
EVIDENCE FOR MARKING
The petitioner will present the following documents.
1. Marriage Certificate between Olivia P. Mercado and Timothy A. Lim made on
December 20, 2010.
2. Marriage Certificate between Rosalie S. Tan and Timothy A. Lim made on
September 14, 2014.

V.
WITNESSES TO BE PRESENTED
The Petitioner will present the following witnesses:
1. Olivia P. Mercado
2. Timothy A. Lim
3. (Civil Registrar)
4. Other witnesses as may be determined to be relevant to the case during the
course of trial.

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 VI.
AVAILABLE DATES FOR TRIAL
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.
Muntinlupa City, 23 January 2017.

MUNTINLUPA PROSECUTORS OFFICE

2nd Floor, Hall of Justice, Tunasan,
Muntinlupa City, 1773 Metro Manila

By:

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

Copy furnished:

ATTY.
Counsel for the Defense
Address

Receive by: ____________

Date: ________________