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PHYSICAL INJURIES, committed as follows, to wit: That on or about _____________, at about _________ (a.m./p.m.), in the City/Municipality of _____________, Province of _____________ and within the jurisdiction of this Honorable Court, the said accused did there and then willfully, unlawfully and feloniously, and without justifiable cause therefor, attack, assault, and beat one _____________ with a baseball bat, resulting to injuries to the latter rendering him in capacitated for labor for a period of more than thirty (30) days. Contrary to law. _____________, Philippines, __Date__. PROSECUTOR Witnesses: ____________________ ____________________ (Certification of Preliminary Investigation) ____________________ ____________________
4. . Accused. Affidavit of the cashier Geraldine Demetri Purpose: to prove that she was on-duty when the robbery took place and that one of the accused pointed a gun at her. the killing of the victim. 3. before this Honorable Court. Affidavit of customer Paris Michaels Purpose: to corroborate the testimonies of Geraldine Demetri and Bea Robles. . 2. Plaintiff. Autopsy Report of Joey Cruz issued by Iloilo Mission Hospital Purpose: to prove the extent of the injury and the cause of death of the victim. x-----------------------------------------------x PRE-TRIAL BRIEF OF THE PROSECUTION THE PEOPLE OF THE PHILIPPINES. EVIDENCE FOR MARKINGS 1. through the undersigned City Prosecutor. 3._______ FOR: ROBBERY WITH HOMICIDE TITO CRUZ AND VIC CRUZ.PEOPLE OF THE PHILIPPINES. who eventually declared hold-up while the other emptied the cash registers and took some grocery stuffs. 2. the identities of those charged in the information and that of the persons arraigned are one and the same. the date and places of the commission of the crime. the victim. Affidavit of customer Bea Robles 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. the identity of Joey Cruz. most respectfully submit this Pre-Trial Brief: SUMMARY OF ADMITTED FACTS AND PROPOSED STIPULATION OF FACTS The following are the admitted facts: 1.versus – Republic of the Philippines Sixth Judicial Region REGIONAL TRIAL COURT Branch___ Iloilo City CRIMINAL CASE NO.
Whether or not they were guilty thereof. . 7.4. T RIAL DATES Specifically all Fridays of the month. Whether or not the accused committed the crime charged. Paris Michaels to testify that she was one of the customers of Iloilo Supemart at the time the robbery took place. Benamarca to testify that he was the police officer who went to the scene of the crime and arrested the accused. Iloilo City. extent and location of wound. . 2. Paraffin test result Purpose: To prove that accused became positive of gun powder burns. Three live ammunitions 11. Anatomical Sketch Purpose: To prove which part of the victim’s body was shot and the nature. Fired Shell 10. Affidavit of Romeo V. 9. 2. Isabel Cenon to testify that she conducted the post mortem examination of Joey Cruz and to attest to the veracity of her findings in the autopsy report. Police Senior Inspector Anthony Villar to testify that he conducted the ballistics examination and to attest to the veracity of his findings in the said report. 5. 4. Ballistics Test result Purpose: To prove that the slug recovered from the victim’s body came from the same gun which was recovered from the possession of Tito Cruz. 6. 3. Blotter Report of Jaro Police Station (ICP-PP3) Purpose: to prove that the police authority received a report that a robbery took place at Iloilo Supermart. Romeo V.7. Jaro. with the regular appearance of the undersigned city prosecutors before this Honorable Court.45 caliber pistol I S S U E S 1. 6. W I T N E S S E S 1. located at Tabuk Suba. Benamarca Purpose: To prove that he personally heard a gun shot from an abandoned rice mill and actually saw the accused holding a gun and the dead body of the deceased which subsequently followed the arrest of the accused. 5. 8. Dra. Geraldine Demetri to testify that a robbery took place. Chemist Dionisia Paqui to testify that she conducted a paraffin test to the accused and to attest to the veracity of her findings in the said report. Bea Robles to testify that she was one of the customers of the Iloilo Supermart at the time the robbery took place.
Philippines.. KENETH P.RESPECTFULLY SUBMITTED. 67890 / 5-2-07 IBP.Iloilo City By: JOHN FRED C. Iloilo. ILOILO CITY PROSECUTOR’S OFFICE Ramon Q. 667900 / 12-29-07 MCLE Exempt PTR Exempt Copy furnished: ATTY. Central Philippine University Lopez Jaena St. No. Jaro. TUPAS Counsel for the Defense Room 200. New Valentine Bldg. 2008. 67891 / 5-2-07 IBP No. July 4. Iloilo City. HALLARES Assistant City Prosecutor Roll No. Iloilo City Received by:___________ Date: ___________ . 667899 / 12-29-07 MCLE Exempt PTR Exempt And JASIE ANN MAGHOPOY Assistant City Prosecutor Roll No. Avanceña Hall of Justice Bonifacio Drive.
Affidavit of accused. Iloilo City. the victim. 2008 at about 1:30 in the morning and at Corner Valeria-De Leon Sts. 3. EVIDENCE FOR MARKINGS 1. 4.D. ALFREDO GOLEZ. x-----------------------------------------------x PRE-TRIAL BRIEF OF THE ACCUSED ACCUSED. 4. Accused. AND GREG FAJARDO. most respectfully submit this Pre-Trial Brief: SUMMARY OF ADMITTED FACTS AND PROPOSED STIPULATION OF FACTS The accused admit the following: 1. the killing of the victim. 2. to Gabriel Salas Purpose: to prove that the accused sustained several wounds as a result of the aggression by the victim. Cielo F. Gabriel Salas Purpose: to prove that he admits the killing of the victim but the same was done in self-defense.Republic of the Philippines Sixth Judicial Region REGIONAL TRIAL COURT Branch___ Iloilo City PEOPLE OF THE PHILIPPINES. through the undersigned counsel. Blotter Report of Molo Police Station (ICP-PP4) Purpose: to prove that the accused Gabriel Salas voluntarily surrendered to the Police authorities. Greg Fajardo and Alfredo Golez Purpose: to prove that they were at the place where the crime was committed but have no participation thereof. the identities of those charged in the information and that of the CRIMINAL CASE NO. the date..versus – GABRIEL SALAS. which was May 5. 2. the identity of Sulpicio Treyes. Medical Report issued by Dra. . Plaintiff. 3. before this Honorable Court. Affidavits of accused. M. ._______ FOR: MURDER persons arraigned are one and the same. Eltonn. place and time of the killing.
M. Iloilo.Whether or not the accused committed the crime charged. 2008 GALLEGO-SABIDO LAW OFFICES Arguelles St. No. Iloilo City. with the regular appearance of the undersigned counsels before this Honorable Court.I S S 1. to testify on the veracity of the findings stated in the medical report of Gabriel Salas. RESPECTFULLY SUBMITTED. U E S W I T N E 1. Iloilo City By: RHONALYN C. 4.Whether or not they were guilty thereof. 890590 / 12-20-07 PTR No. S S E S 3. 890591 / 12-20-07 PTR no. 345668 / 01-05-08 . June 2.. Dra. Witness Jason Pilas-Pilas to testify on the exchange of words and blows between the accused Gabriel Salas and the deceased which resulted to the death of the victim. Cielo F. 2.D. GALLEGO Counsel for the Defense Roll No. Eltonn. 789085 / 12-29-07 MCLE Compliance No. Accused Gabriel Salas to testify on the matters and circumstances attending the killing of the victim. SABIDO Counsel for the Defense Roll No. Accused Alfredo Golez and Greg Fajardo to testify on their nonparticipation on the killing. T RIAL DATES Specifically all Fridays of the month. 345667 / 01-05-08 And EVANGELINE S. Philippines. 2. No. 789084 / 12-29-07 MCLE Compliance No. 69009 / 5-2-07 IBP. 68999 / 5-2-07 IBP. Jaro.
Copy furnished: PROS. SHYR PHOEBE F. Avanceña Hall of Justice Bonifacio Drive. REGUETA Assistant City Prosecutor Ramon Q. Iloilo City Received by:___________ Date: ___________ .
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