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Republic of the Philippines Sixth Judicial Region REGIONAL TRIAL COURT Branch___ Roxas City PEOPLE OF THE PHILIPPINES,

Plaintiff$ + ,ersus + TITO CRUZ AND VIC CRUZ, Accused# x+++++++++++++++++++++++++++++++++++++++++++++++x PRE-TRIAL BRIEF OF THE PROSECUTION THE PEOPLE OF THE PHILIPPINES, through the undersigned City Prosecutor$ before this -onorable Court$ .ost respectfully sub.it this Pre+/rial Brief& SUMMARY OF ADMITTED FACTS AND PROPOSED STIPULATION OF FACTS /he follo0ing are the ad.itted facts& 1# the identities of those charged in the infor.ation and that of the persons arraigned are one and the sa.e2 3# the identity of Joey Cru4$ the ,icti.2 5# the 6illing of the ,icti.2 7# the date and places of the co..ission of the cri.e# EVIDENCE FOR MARKINGS 1# Affida,it of the cashier 8eraldine *e.etri Purpose& to pro,e that she 0as on+duty 0hen the robbery too6 place and that one of the accused pointed a gun at her$ 0ho e,entually declared hold+up 0hile the other e.ptied the cash registers and too6 so.e grocery stuffs2 3# Affida,it of custo.er Bea Robles Purpose& to pro,e that she 0as one of the custo.ers at the ti.e the robbery too6 place and that she sa0 and identified the accused by their faces2 5# Affida,it of custo.er Paris (ichaels Purpose& to corroborate the testi.onies of 8eraldine *e.etri and Bea Robles2 5# Autopsy Report of Joey Cru4 issued by Iloilo (ission -ospital Purpose& to pro,e the extent of the in9ury and the cause of death of the ,icti.2 7# Blotter Report of Jaro Police Station :ICP+PP5; Purpose& to pro,e that the police authority recei,ed a report that a robbery too6 place at Iloilo Super.art$ located at /abu6 Suba$ Jaro$ Iloilo City# <# Affida,it of Ro.eo V# Bena.arca CIVIL CAS !"#_______ %"R& R C'L SS I(PR)* !C

Purpose& /o pro,e that he personally heard a gun shot fro. an abandoned rice .ill and actually sa0 the accused holding a gun and the dead body of the deceased 0hich subse=uently follo0ed the arrest of the accused# ># Paraffin test result Purpose& /o pro,e that accused beca.e positi,e of gun po0der burns# ?# Anato.ical S6etch Purpose& /o pro,e 0hich part of the ,icti.@s body 0as shot and the nature$ extent and location of 0ound. A# Ballistics /est result Purpose& /o pro,e that the slug reco,ered fro. the ,icti.@s body ca.e fro. the sa.e gun 0hich 0as reco,ered fro. the possession of /ito Cru4# B# %ired Shell 1C# /hree li,e a..unitions 11# #7< caliber pistol ISSUES 1# Dhether or not the accused co..itted the cri.e charged2 3# Dhether or not they 0ere guilty thereof# WITNESSES 1# 8eraldine *e.etri to testify that a robbery too6 place2 3# Bea Robles to testify that she 0as one of the custo.ers of the Iloilo Super.art at the ti.e the robbery too6 place2 5# Paris (ichaels to testify that she 0as one of the custo.ers of Iloilo Supe.art at the ti.e the robbery too6 place# 7# Ro.eo V# Bena.arca to testify that he 0as the police officer 0ho 0ent to the scene of the cri.e and arrested the accused# <# *ra# Isabel Cenon to testify that she conducted the post .orte. exa.ination of Joey Cru4 and to attest to the ,eracity of her findings in the autopsy report# ># Police Senior Inspector Anthony Villar to testify that he conducted the ballistics exa.ination and to attest to the ,eracity of his findings in the said report# ?# Che.ist *ionisia Pa=ui to testify that she conducted a paraffin test to the accused and to attest to the ,eracity of her findings in the said report# TRIAL DATES Specifically all %ridays of the .onth$ 0ith the regular appearance of the undersigned city prosecutors before this -onorable Court# RESPECTFULLY SUBMITTED. Iloilo City$ Iloilo$ Philippines$ July 7$ 3CCA#

ILOILO CITY PROSECUTORS OFFICE


Ra.on E# A,anceFa -all of Justice Bonifacio *ri,e$Iloilo City

By& JOHN FRED C. HALLARES


Assistant City Prosecutor Roll !o# >?ABC G <+3+C? IBP# !o# >>?ABB G 13+3B+C? (CL xe.pt P/R xe.pt

And

JASIE ANN MAGHOPOY


Assistant City Prosecutor Roll !o# >?AB1 G <+3+C? IBP !o# >>?BCC G 13+3B+C? (CL xe.pt P/R xe.pt

Copy furnished& ATTY. KENETH P. TUPAS Counsel for the *efense Roo. 3CC$ !e0 Valentine Bldg# Central Philippine )ni,ersity Lope4 Jaena St#$ Jaro$ Iloilo City

Recei,ed by&___________ *ate& ___________