PLASOS, MA. KATRINA VI C.

LEGAL TECHNIQUE

Republic of the Philippines

10th Judicial Region
REGIONAL TRIAL COURT
Branch 50
Cagayan de Oro City

PEOPLE OF THE PHILIPPINES, CRIMINAL CASE NO. 1234

Plaintiff,

- versus - FOR:
ROBBERY WITH HOMICIDE

JUAN DELA CRUZ AND REX CRUZ,

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

PRE-TRIAL BRIEF OF THE PROSECUTION

THE PEOPLE OF THE PHILIPPINES, through the

undersigned City Prosecutor, before this Honorable Court, most
respectfully submit this Pre-Trial Brief:
SUMMARY OF ADMITTED FACTS
AND PROPOSED STIPULATION OF FACTS
The following are the admitted facts:
1. the identities of those charged in the information and
that of the persons arraigned are one and the same;
2. the identity of John Lloyd Cruz, the victim;
3. the killing of the victim;
4. the date and places of the commission of the crime.
EVIDENCE FOR MARKINGS
1. Affidavit of the cashier Angel Locsin
Purpose: to prove that she was on-duty when the robbery took
place and that one of the accused pointed a gun at her, who
eventually declared hold-up while the other emptied the cash
registers and took some grocery stuffs;
2. Affidavit of customer Bea Santos
Purpose: to prove that she was one of the customers at the
time the robbery took place and that she saw and identified the
accused by their faces;
3. Affidavit of customer Piolo Pascual
Purpose: to corroborate the testimonies of Angel Locsin and
Bea Santos;
3. Autopsy Report of John Lloyd Cruz issued by Northern
Mindanao City Hospital
Purpose: to prove the extent of the injury and the cause of
death of the victim;
4. Blotter Report of Macasandig Police Station
Purpose: to prove that the police authority received a report
that a robbery took place at Chams Convenient Store, located
at Macasandig, Cagayan de Oro City.
5. Affidavit of Vhong Navarro
Purpose: To prove that he personally heard a gunshot from the
store and actually saw the accused holding a gun and the dead
body of the deceased which subsequently followed the arrest of
the accused.
6. Paraffin test result
Purpose: To prove that accused became positive of gun powder
burns.
7. Anatomical Sketch
Purpose: To prove which part of the victims body was shot and
the nature, extent and location of wound.
8. Ballistics Test result
Purpose: To prove that the slug recovered from the victims
body came from the same gun which was recovered from the
possession of Rex Cruz.
9. Fired Shell
10. Three live ammunitions
11. .45 caliber pistol
ISSUES
1. Whether or not the accused committed the crime
charged;
2. Whether or not they were guilty thereof.
WITNESSES
1. Angel Locsin to testify that a robbery took place;
2. Bea Santos to testify that she was one of the
customers of Chams Convenient Store at the time the robbery
took place;
3. Piolo Pascual to testify that he was one of the
customers of Chams Convenient Store at the time the robbery
took place.
4. Vhong Navaroo to testify that he was the police officer
who went to the scene of the crime and arrested the accused.
5. Dra. Isabel Daza to testify that she conducted the post
mortem examination of Richard Gomez and to attest to the
veracity of her findings in the autopsy report.
6. Police Senior Inspector Coco Martin to testify that he
conducted the ballistics examination and to attest to the
veracity of his findings in the said report.
7. Chemist Bella Padilla to testify that she conducted a
paraffin test to the accused and to attest to the veracity of her
findings in the said report.
 TRIAL DATES
Specifically all Fridays of the month, with the regular
appearance of the undersigned city prosecutors before this
Honorable Court.
RESPECTFULLY SUBMITTED.
Cagayan de Oro City, Misamis Oriental, Philippines,
January 4, 2017.

CAGAYAN DE ORO CITY

PROSECUTORS OFFICE
Hall of Justice

By:

MAJA SALVADOR
Assistant City Prosecutor
Roll No. 67890 / 5-2-07
IBP. No. 667899 / 12-29-07
MCLE Exempt
PTR Exempt

And

JODIE STA. MARIA

Assistant City Prosecutor
Roll No. 67891 / 5-2-07
IBP No. 667900 / 12-29-07
MCLE Exempt
PTR Exempt
Copy furnished:

ATTY. MARIAN RIVERA

Counsel for the Defense
Room 200, New Valentine Bldg.
Cagayan de Oro City

Received by:___________
Date: ___________