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Republic of the PhilippinesSixth Judicial Region REGIONAL TRIAL COURT Branch___Roxas City PEOPLE OF THE PHILIPPINES, CIVIL CASE

NO._______P l a i n t i f f , F O R : RECKLESS IMPRUDENCE- versus TITO CRUZ AND VIC CRUZ, Accused.x-----------------------------------------------x PRE-TRIAL BRIEF OF THE PROSECUTIONT H E P E O P L E O F T H E P H I L I P P I N E S , t h r o u g h t h e u n d e r s i g n e d C i t y Prosecutor, 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 . t h e i d e n t i t i e s o f t h o s e c h a r g e d i n t h e i n f o r m a t i o n a n d t h a t o f t h e persons 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.5. Affidavit of Romeo V. Benamarca