Republic of the Philippines

Regional Trial Court

6th Judicial Region
C.I.R.Q Avancena Hall of Justice
Bonifacio Drive, Iloilo City

THE PEOPLE OF THE PHILIPPINES,

Plaintiff .

I.S NO. 2008-1664

CRIM. CASE NO__
FOR :VIOL. OF P.D 1886
AS AMENDED BY R.A 8294

-versusCHRISTOPHER TALAMOR y HAUTEA

Accused.
x-------------------------------------------x

MEMORANDUM FOR THE ACCUSED

COMES NOW Accused, through the evidences presented by the Leganes PNP
and through the undersigned Prosecutor to this honorable court, respectfully
submits the memorandum.
PRELIMINARY STATEMENT
This is a case for illegal possession of firearms under P.D 1886 as amended
by R.A 8294 filed by CINSP Orlando Colisao, Chief of Police of Leganes Iloilo
against Christopher Hautea Talamor resident of Brgy, Sulangan, Dumangas, Iloilo.
FACTS OF THE CASE
CHRISTOPHER TALAMOR y HAUTEA, 37 years old, married and a
resident of Barangay Sulangan, Dumangas, Iloilo with standing Warrant of Arrest
in Criminal Case No. 08-65131, for Murder, issued by Judge Danilo P. Galvez,
RTC 6, Iloilo City dated February 18, 2008. That upon serving the said warrant of
arrest, he was caught with illegal possession of firearm and ammunition, hence the
present case.
On October 07, 2008, at about 7:00 oclock in the morning, Chief Inspector Fusin
Jr. together with the personnel of Regional Intelligence Office 6 coordinated thru
PO3 Mars Cornell Heso of Leganes Municipal Police Station to accompany them
to conduct intelligence monitoring and surveillance on any forms of illegal
activities around Municipality of Leganes.

At about 10:00 oclock in the morning of the same date, the team went back to the
Leganes Municipal Police Station for a briefing that was conducted by Chief
Inspector Sofronio Fusin Jr. and Chief Inspector Orlando R. Colisao for the
purpose of serving the warrant of arrest to CHRISTOPHER TALAMOR y
HAUTEA spotted at Manuela Subdivision, Leganes, Iloilo.
On 11:50 in the morning, the team proceeded to Manuela Subdivision to arrest the
respondent, being an accused in Criminal Case No. 08-65131, for Murder, at the
sala of Judge Danilo P. Galvez, RTC 6, Iloilo City.
Upon arriving at Manuela Subdivision, the team rushed towards Porras Residence
where the accused was spotted as given by their informant. Some of them went
inside the house to verify the presence of the accused but he was not found there
and was able to escape.
A thorough search was done, wherein they surrounded the possible place where
Christopher Talamor was hiding. PO3 Heso, SPO3 Jalandoni and PO1 Robles
went to the grassy area near the back of Villa Feliza concrete wall and were able to
see a man hiding his body in the thick grass and shrubs in a prone position wearing
blue short pants and without a shirt. They ordered him to get out from where he
was hiding which he did so.
A 0.45 caliber pistol was seen tucked at the right portion of Talamors waist. PO3
Heso ordered him to lie on the ground facing down with both hands at the back of
his head, which he also did. The firearm was taken from his possession and he was
handcuffed by PO3 Heso and the other two policemen served as back up.
The accused was asked if he has an authority or license to possess said firearm and
he replied none. They placed him under arrest and informed of his Constitutional
Rights under the Miranda Doctrine. He was also informed that he has a standing
warrant of arrest in Criminal Case No. 08-65131, for Murder, a non-bailable
offense, issued and signed by Judge Danilo P. Galvez of RTC 6, Iloilo City dated
February 18, 2008.
The accused was detained at Leganes Municipal Detention Cell for proper
disposition.
EVIDENCES FOR THE PROSECUTION
Attachments :
1. Affidavit of Arrest of Apprehending Officers
2. Police Blotter Extract
3. Medical Certificate of the Suspect

4. Xerox Copy Of warrant of Arrest

Exhibits: A5 caliber pistol MK. IV(Series 80), With magazine and seven live
ammunitions(7) with serial # 288187.
Issue
Whether or not the accused is guilty beyond reasonable ground for illegal
possession of firearm.
ARGUMENTS AND DISCUSSIONS
The accused must be held guilty beyond reasonable ground for the
violation of P.D 1886 as amended by R.A 8294. The accused willfully and
feloniously had in his possession a 45 caliber pistol and when he was arrested and
he admitted that he did not secure any license for the said firearm. There was a
clear and convicing admittance of the accused that he owns the unlicensed firearm
and the policemen (SPO3 Heso,SPO3 Jalandoni, and SPO1Robles) who
apprehended him were easily convinced that the accused is guilty of illegal
possession of firearms. It is unlawful for a person not permitted or authorized by
law to carry firearms without licensed. The accused must be convicted for the
crime he violated.
If there is admittance of the accused for the crime charged against him, judgment
or conviction must be immediately rendered to him so that justice may prevail.
We on the prosecution found that the accused Christopher Talamor Hautea guilty
of charge against him.
PRAYER
WHEREFORE, in view of all the foregoing, it is respectfully prayed by the
honorable court that the decision be issued convicting the accused of charges
against him.
Other reliefs and remedies are just and equitable in the premises are likewise
prayed for.

Memorandum
submitted for
resolution.

Submitted to: Judge Ma. Dianela Ladrido

Submitted by: Jethro Villaruel L.lB 1-B

Memorandum
(For the conviction of the
accused CHRISTOPHER
TALAMORHAUTEA)