Republic of the PhilippinesSixth Judicial Region
REGIONAL TRIAL COURT
PEOPLE OF THE PHILIPPINES,
CRIMINAL CASE NO._______Plaintiff,FOR:ROBBERY WITH HOMICIDE- versus -
TITO CRUZ AND VIC CRUZ,
PRE-TRIAL BRIEF OF THE PROSECUTIONTHE PEOPLE OF THE PHILIPPINES,
through the undersigned CityProsecutor, before this Honorable Court, most respectfully submit this Pre-TrialBrief:
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 thepersons arraigned are one and the same;2. the identity of Joey 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 Geraldine DemetriPurpose: to prove that she was on-duty when the robbery took place and thatone of the accused pointed a gun at her, who eventually declared hold-up whilethe other emptied the cash registers and took some grocery stuffs;2. Affidavit of customer Bea RoblesPurpose: to prove that she was one of the customers at the time the robberytook place and that she saw and identified the accused by their faces;3. Affidavit of customer Paris MichaelsPurpose: to corroborate the testimonies of Geraldine Demetri and Bea Robles;3. Autopsy Report of Joey Cruz issued by Iloilo Mission HospitalPurpose: to prove the extent of the injury and the cause of death of the victim;4. Blotter Report of Jaro Police Station (ICP-PP3)Purpose: to prove that the police authority received a report that a robbery tookplace at Iloilo Supermart, located at Tabuk Suba, Jaro, Iloilo City.