Republic of the Philippines

Eleventh Judicial Region

MUNICIPAL TRIAL COURT
Baganga, Davao Oriental

ELLA CAMPAVILLA, CIVIL CASE NO._______

Plaintiff, FOR: DAMAGES FOR ALIENATION
OF AFFECTION

- versus -

SARAH GERONIMO,
Defendant.
x-----------------------------------------------x

PRE-TRIAL BRIEF OF THE DEFENDANT

DEFENDANT, through the undersigned counsel, before

this Honorable Court, most respectfully submit this Pre-Trial
Brief:

SUMMARY OF ADMITTED FACTS

AND PROPOSED STIPULATION OF FACTS

The defendant admits the following:

1. The identity of that charged in the complaint;
2. The identity of Ella Campavilla, the complainant;
3. The May 1, 2015 incident, including the place, and
time;

EVIDENCE FOR MARKINGS

1. Affidavit of the defendant, SARAH GERONIMO

Purpose: To prove that she admits the act committed on May
1, 2015, but the same was committed not to alienate affection;
 2. Affidavit of witness, RUFFA CAMPAVILLA-GUTIERREZ,
sister of RON CAMPAVILLA, husband of the complainant
Purpose: To prove that the marriage of the complainant with
RON CAMPAVILLA, was marred with controversies due to her
own acts of immorality and infidelity since the beginning;

3. Affidavit of witness, PAULO AVELINO, driver of the

complainant
Purpose: To prove that the complainant had an affair with the
above named witness, causing a severe strain on the marital
relationship of the complainant with her husband, prior to the
acts complained of in this instant case;

4. Blotter Report of Baganga Police Station (ICP-PP69)

Purpose: To prove that the complainant was caught with
PAULO AVELINO by RON CAMPAVILLA, on Chirstmas Eve of
2014, performing vile acts inside the car of the complainant,
where RON VILLACAMPA, sustained physical injuries inflicted
by the driver, PAOLO AVELINO, where he voluntarily
surrendered to the Police authorities.

ISSUES

1. Whether or not the defendant committed the complaint

charged;
 WITNESSES

1. Defendant SARAH GERONIMO to testify on the matters

and circumstances attending the complaint charged;

2. RUFFA CAMPAVILLA-GUTIERREZ, sister of RON

CAMPAVILLA, husband of the complainant, to testify that the
marriage of the complainant with RON CAMPAVILLA, was
marred with controversies due to her own acts of immorality
and infidelity since the beginning;

3. PAULO AVELINO, driver of the complainant, to testify

that the complainant had an affair with the above named
witness, causing a severe strain on the marital relationship of
the complainant with her husband, prior to the acts complained
of in this instant case;

TRIAL DATES

Specifically all Fridays of the month, with the regular

appearance of the undersigned counsels before this Honorable
Court.

RESPECTFULLY SUBMITTED.

Banganga, Davao Oriental, Philippines, June 2, 2008

By:

RHONALYN C. GALLEGO
 Counsel for the Defense
Roll No. 68999 / 5-2-07
IBP. No. 789084 / 12-29-07
MCLE Compliance No. 890590 /
12-20-07
PTR No. 345667 / 01-05-08

Copy furnished:

PROS. SHYR PHOEBE F. REGUETA

Assistant City Prosecutor
Ramon Q. Avanceña Hall of Justice
Bonifacio Drive, Iloilo City

Received by:___________
Date: ___________