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Prosec: Mr. witness, during the direct examination youve mentioned that youve been working as a
security guard for 8 years, that is from 2005- present. Yes or no?
Prosec: Mr. witness, youve also testified that last Oct. 30, 2004, you were already assigned at 7/11
Masangkay branch as security guard. Yes or no?

Prosec: Since as per your testimonies you are a security guard up to present, may we know where are
you currently assigned?
Prosec: Mr. Witness, youve mentioned that prior to Oct. 30, 2004 you dont remember any incident or
conflict with any person or co-worker in 7/11 Masangkay branch. Yes or no?
Prosec: and that youve been with Masangkay branch for less than a month or that is less than 30 days?
Yes or no?
Prosec: when you said you dont remember any incident or conflict with any person, may it also mean
that there was an incident or conflict but its just that you dont remember it? Yes or no.
[If answer is no, ask him about something in his life that he remembers, like most unforgettable fight
with family members, most hurtful event in life. For us to establish that the witness really doesnt want
to remember his fight with Guadalupe prior to Oct. 30, it is not merely because he doesnt remember it.
Also to show that the witness doesnt have a good memory thus, he is not a credible witness.]
Prosec: Youve mentioned that you came to know Mark Dave Guadalupe because he delivers products
to 7/11 every week during Mondays. Correct?
Prosec: Last Oct. 30, 2004 you met Guadalupe in the store right?
Prosec: Last oct. 30, 2004, it was Saturday, would you agree?
Prosec: You said Guadalupe is in medium built and 55 in height, may we know whats yours?
Prosec: During the direct examination, youve mentioned that Last Oct. 30,2004, Guadalupe asked you
to help him carry the products from the delivery van to the storage room, and you did it simultaneously
Prosec: Simultaneously means salitan?
Prosec: When Maricar Martinez called you to keep an eye on the money she was then counting, you said
Guadalupe was then inside the storage room right?

Prosec: And you were outside the storage room?

Prosec: I just want to clarify, since Guadalupe was then already inside the storage room, when you
entered, what was your relative position with each other?
[establish that Valencia was by then at the back of Guadalupe]
Prosec: Were you at his back? Yes or no?
Prosec: You said during the direct exam that your distance with each other was about 3.5 meters right?
Prosec: Since you were at his back and about 3.5m away, did you clearly see Guadalupe pocketed a 1000
peso bill?
Prosec: What is your vision Mr. witness?
[Much better if we can demo, lets say a table with money bills, preferably 1000 and 100, then Valencia
facing someones back at about 3.5m, if he can identify what bill does the said person holds]
Prosec: youre testimony was that you saw him binulsa yung 1000, you did not saw him picked-up the
said bill?
(If nakita nya pgkuha)
Prosec: Do you have any idea where is that 1000 bill now?
(Since the unlawful taking of the said money is the root of their defense, it should have been confiscated
or presented as evidence. But since, they have 2 more witnesses, maybe theyll present it. Sana hindi.)
Prosec: You testified that when you confronted Guadalupe to return the money, he did not responded
to you and instead pushed you. Yes or no?
Prosec: You also said that when Guadalupe was already running towards the store, you noticed him
carrying a knife?
Prosec: Earlier, when he pushed you, you did not notice him carrying a knife?
Prosec: You said, the knife came from the storage room right?
Prosec: do you know why there is a knife inside the storage room?
Prosec: So, aside from the products that youve mentioned during the direct examination, such as
breads, canned goods, there is also a knife inside the storage room?
Prosec: did you actually saw him get the said knife?
Prosec: Where at the storage room?

Prosec: When you catched Guadalupe in the store, you said winasiwas nya yung hawak nyang knife.
Do you recall if there was any customer that time?
Prosec: What was the reaction of the customer/crews that time?
Prosec: On that moment, are you holding your gun? Yes or no?
Prosec: in your testimony, there were two attempts from Guadalupe to stab you and you were just able
to avoid the same right?
Prosec: On the second attempt, you said you were able to avoid him because you stumbled and rolled
over, right?
Prosec: In your testimony you said you did not see any other means for your defense so, to quote it,
naisipan mo na barilin nalang siya dahil aggressive siya, right?
Prosec: when you shot him, you were then lying on the floor?
Prosec: what was your relative position with each other when you shot him?
Prosec: What was the distance?
Prosec: after you shot him, you said you asked help from Ulric Reyes and Maricar Martinez and the
latter responded by checking Guadalupes pulse right?
Prosec: after that, you said you went outside the store to asked help from other person and on that time
you came to meet Sapiendante, right?
Prosec: When you came to meet Sapiendante, were you running that time or what?
(dapat naka-bike siya)
Prosec: You said, you were so confused that time. Why?
Prosec: You said, you left the store to ask help from someone you know in the police station, right?
Prosec: may we know who is that someone you know?
Prosec: What police station is that?
[Study the nearest police stations in Masangkay and from where he was apprehended, I think that was
Ilaya St., study the direction if its contradicting.]
Prosec: In your testimony, you said you were able to reach the police station. Yes or no?
Prosec: Were you able to meet the one you know in that station? Yes or no.
Prosec: In your testimony also, you said you voluntarily surrendered right? yes or no.

Prosec: I thought you sought help. So, you voluntarily surrendered for what?
Prosec: In your testimony, you said the policemen confiscated your bag and found there a gun and your
uniform right?
Prosec: what gun was that?
[during the direct, the witness cannot properly identify a revolver from a pistol]
Prosec: You said, your uniform inside the bag was also found. Yes or no?
Prosec: you were able to change clothes? Yes or no.
Prosec: In your testimony, you said that the last thing you did was you waited for a counsel. Yes or no?
Prosec: Were you provided with one?
Prosec: Were you detained?
Prosec: Since youve mentioned that youve been a security guard from 2005-present, when did you
resume working as a security guard after you have been detained? ,)
Prosec: That would be all for the cross, your honor.

*** please edit

-Ida Marie ;)