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Republic of the Philippines

National Capital Judicial Region
REGIONAL TRIAL COURT
Branch___
Manila city
PEOPLE OF THE PHILIPPINES,
Plaintiff,

CRIMINAL CASE NO._______
FOR:
ROBBERY WITH HOMICIDE

- versus MARK MAANGAS,
Accused.
x-----------------------------------------------x
PRE-TRIAL BRIEF OF THE PROSECUTION
THE PEOPLE OF THE PHILIPPINES, through the undersigned City
Prosecutor, before this Honorable Court, most respectfully submit this Pre-Trial
Brief:
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 the
persons arraigned are one and the same;
2. the identity of ADIC ADICTU, 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 JANE MALAS
Purpose: to prove that she was on-duty when the robbery took place and that
one of the accused pointed a gun at her, who eventually declared hold-up while
the other emptied the cash registers and took some grocery stuffs;
2. Affidavit of customer GAN GANDA
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. Affidavit of customer ABY PRETI
Purpose: to corroborate the testimonies of JANE MALAS and GAN GANDA;
3. Autopsy Report of ADI ADICTU issued by Iloilo Mission Hospital
Purpose: to prove the extent of the injury and the cause of death of the victim;
4. Blotter Report of MANILA Police Station
Purpose: to prove that the police authority received a report that a robbery took
place at savemore, located at Taft Manila City.

Whether or not the accused committed the crime charged. RESPECTFULLY SUBMITTED. POL TUL to testify that he was the police officer who went to the scene of the crime and arrested the accused. 2. Affidavit of RIN NIG 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. 2015. Philippines. Dra.45 caliber pistol ISSUES 1. MANILA CITY. Anatomical Sketch Purpose: To prove which part of the victim’s body was shot and the nature. 6. Three live ammunitions 11. with the regular appearance of the undersigned city prosecutors before this Honorable Court. GAN GANDA to testify that she was one of the customers of the Iloilo Supermart at the time the robbery took place. 7. Paraffin test result Purpose: To prove that accused became positive of gun powder burns. Fired Shell 10. 8. JANE MALAS to testify that a robbery took place. 6.5. 3. Iloilo. 4. WITNESSES 1. . February 24. 7. extent and location of wound. 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 BAR RIL. 9. TRIAL DATES Specifically all Fridays of the month. 2. SABEL GAL 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 POUL POL to testify that he conducted the ballistics examination and to attest to the veracity of his findings in the said report. Chemist GIL MANG to testify that she conducted a paraffin test to the accused and to attest to the veracity of her findings in the said report. Whether or not they were guilty thereof. ABY PRETI to testify that she was one of the customers of Iloilo Supemart at the time the robbery took place.

PANALO WIN Counsel for the Defense ESPANYA MANILA CITY Received by:___________ Date: ___________ Assistant City Prosecutor Roll No IBP NoMCLE Exempt PTR Exempt . MCLE Exempt PTR Exempt And OLAT TALO Copy furnished: ATTY.MANILA City By: TALO PALO Assistant City Prosecutor Roll No. No. IBP.MANILA CITY PROSECUTOR’S OFFICE ROCKY PANALO Hall of Justice TAFT.