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Adultery: 3Rd Municipal Circuit Trial Court of Pinukpuk-Rizal

Mary Jill Dallapas and Neldon Awingan have been charged with adultery. They have submitted a pre-trial brief to the court admitting that Mary Jill and Eddie Dallapas were married in 2006 and have two children, but that they have had an estranged relationship since 2013 due to Eddie's jealousy and paranoia. They are proposing stipulations that Eddie did not provide financial support to the family and that Neldon did not know of Mary Jill's marital status. The defense will argue that the evidence does not prove adultery beyond reasonable doubt and that the accused cannot be held liable. Mary Jill and Neldon will testify in their defense. The defense is open to a reasonable settlement.

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Christina Pic-it Baguiwan
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153 views

Adultery: 3Rd Municipal Circuit Trial Court of Pinukpuk-Rizal

Mary Jill Dallapas and Neldon Awingan have been charged with adultery. They have submitted a pre-trial brief to the court admitting that Mary Jill and Eddie Dallapas were married in 2006 and have two children, but that they have had an estranged relationship since 2013 due to Eddie's jealousy and paranoia. They are proposing stipulations that Eddie did not provide financial support to the family and that Neldon did not know of Mary Jill's marital status. The defense will argue that the evidence does not prove adultery beyond reasonable doubt and that the accused cannot be held liable. Mary Jill and Neldon will testify in their defense. The defense is open to a reasonable settlement.

Uploaded by

Christina Pic-it Baguiwan
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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Republic of the Philippines

3rd MUNICIPAL CIRCUIT TRIAL COURT OF


PINUKPUK-RIZAL
Second Judicial Region
Pinukpuk, Kalinga

PEOPLE OF THE PHILIPPINES, CRIMINAL CASE NO. 480-


Plaintiff, 2020

-versus-
FOR ADULTERY

MARY JILL DALLAPAS y KIBAYEN


AND NELDON AWINGAN,
Accused
x----------------------------------------------------------x

PRE-TRIAL BRIEF FOR THE ACCUSED

ACCUSED, MARY JILL K. DALLAPAS AND NELDON AWINGAN, through


the undersigned counsels respectfully submits for the consideration of this Honorable
Court the folowing:

I. ADMITTED FACTS

1. The identity of the persons charged in the information and of the persons
arraigned are one and the same.
2. The jurisdiction of this Honorable Court.
3. The marriage between accused, Mary Jill Kibayen Dallapas and Eddie
Dallapas on August 7, 2006.
4. That the accused, Mary Jill K. Dallapas and Eddie Dallapas’ marriage
resulted the birth of their two (2) children.

II. PROPOSED STIPULATIONS OF FACTS

Will the prosecution admit:

1. That since 2013, accused, Mary Jill and the private complainant, Eddie
Dallapas has an estranged relationship.
2. That during their marriage, they occasionally quarrel because of
Eddie’s jealousy and paranoia that his wife is having an affair with her
workmates.
3. That Eddie Dallapas was not giving financial support to his family
since _______.
4. That accused, Neldon Awingan did not know that

ISSUES
1. Does the evidence meet the quantum of proof to convict the accused beyond
reasonable doubt of the CRIME OF ADULTERY?
2. Whether or not the accused can be held liable for Adultery.

WITNESSES

1. Mary Jill Dallapas


2. Neldon Awingan

DEFENSE RESERVES THE RIGHT TO PRESENT ADDITIONAL DOCUMENTARY


AND TESTIMONIAL EVIDENCE IN THE COURSE OF TRIAL.

DEFENSE IS AMENABLE TO ENTER INTO COMPROMISE SETTLEMENT


UNDER TERMS THAT ARE REASONABLE

TRIAL DATES

THE DEFENSE SUBMITS TO THE CALENDAR OF CASES


OF THIS HONORABLE COURT as well as of the Hon. Public Prosecutor. It is humbly
prayed for one (1) trial date per witness.

RESPECTFULLY SUBMITTED. Tabuk City, Kalinga, Philippines this 20th day of July
2021.

PIC-IT – GUMABOL – ASTUDILLO


LAW OFFICES
Counsel for the Accused Mary Jill Dallapas
2F Galming Building, Purok 6, Bulanao,
Tabuk City, Kalinga

By:

ATTY. JOHN PAUL S. BAGUIWAN


IBP No.: 131701, Kalinga Chapter
PTR No.: 1538973; 01/24/2020; Tabuk City, Kalinga
MCLE Compliance: Exempt – Admitted June 17, 2019
Roll No. 72685, 06/17/2019, Manila
Contact No: 097559362585
Email Address: [email protected]

AND

ATTY. FEBELYN D. DALUPING


Daluping Law Office
Along LTO Rd., Hilltop, Purok 6,
Bulanao, Tabuk City, Kalinga
IBP NO.: 146548 / 02-08-2021
PTR No: 3241842 / 01-12-2021
ROLL NO 72780
MCLE Compliance No: admitted 06-17-2019
CP Nos: 09175251060 / 092010923927

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