Republic of the Philippines
Third Judicial Region
REGIONAL TRIAL COURT
Branch 20 Pasay City
PEOPLE OF THE PHILIPPINES,
Plaintiff,
CRIMINAL CASE no. 12345
FOR: PARRICIDE
-versus-
Hero L. Santos
Accused.
x-----------------------------------------------x
PRE-TRIAL BRIEF OF THE PROSECUTION
T H E P E O P LE O F T HE P HI LIP 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 Ci 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. The identity of the person charged in the
i n f o r m a t i o n a n d t h a t o f t h e person arraigned is one
and the same;
2. The identity of Gemma Santos, the victim;
3. Lawful arrest without warrant of the accused.
4. The killing of the victim was with intent by the accused.
5. The date and places of the commission of the crime.
6. The butterfly knife “balisong” used by the accused in
stabbing the victim.
7. That the accused Hero Santos is guilty thereof of the crime
Murder under Art. 246 of the Revised Penal Code.
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EVIDENCE FOR MARKINGS
1. Marriage Certificate
Purpose: To prove that the private complainant is the lawful
husband of the deceased.
2. Death Certificate
Purpose: To prove the date, location and cause of death.
3. Birth Certificate
Purpose: To prove that the accused is the son of the deceased.
4. Affidavit of the Arresting Officer
Purpose: To prove that there was indeed commission of killing
of the deceased and lawful arrest without warrant of the
accused.
5. Affidavit of the Investigator on Case
Purpose: To prove that all documents to be presented were
based thru lawful investigation.
6. Photograph of the deceased
Purpose: To prove the identity of the victim Gemma Santos.
7. Pieces of Evidence “Balisong”
Purpose: To prove that the “balisong” was used as the deadly
weapon to consummate the said crime.
8. Serology/Forensic Examination
Purpose: To prove that the “balisong” used was matched in the
serology examination
9. Autopsy Result of Gemma Santos
Purpose: To prove the cause of death and the state of
health prior to death
10. Affidavit of Philip Santos, husband of the victim.
Purpose: to prove that he has personal knowledge in the
commission of the crime.
11. Affidavit of Dra. Maria Isadora Argiente
Purpose: to prove the authenticity of Autopsy Report;
12. Spot Report of Pasay Police Station
Purpose: To establish all evidence leading to the guilt of the
accused
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13. Photographs inside the house of Mr. and Mr. Santos
Purpose: to prove that the place of commission of the crime is
exactly the same with the address of the accused.
14. Finger prints result
Purpose: To prove that the result matches with finger prints
found in the “balisong”
15. Anatomical Sketch
P u r p o s e : To p r o ve wh i c h p a r t o f t h e vi c t i m’ s b o d y
wa s s t a b b e d a n d t h e n a t u r e , extent and location of
wound.
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ISSUES
1. Whether or not the accused committed the crime
charged;
2. Whether or not the accused is guilty thereof.
WITNESSES
1 . P h i l i p S a n t o s – t h e h u s b a n d o f t h e vi c t i m a n d h a s
p e r s o n a l k n o wl e d g e o f t h e c r i m e c o m mi t t e d .
2 . P O 2 J a i me L . D i m a g i b a – A r r e s t i n g O f f i c e r , t o
t e s t i f y t h a t t he a c c u s e d wa s l a wf u l l y a r r e s t e d
wi t h o u t wa r r a n t
3 . S P O 2 Ri c k y Da l i s a y – Ca s e I n ve s t i g a t o r , t o t e s t i f y
t h e ve r a c i t y o f t h e p i e c e s o f e vi d e n c e a c q u i r e d
d u r i n g t h e c a s e i n ve s t i g a t i o n .
4. D r a . M a r i a I s a d o r a A r g i e n t e - t o t e s t i f y t h a t
s h e c o n d u c t e d t h e p o s t - m o r t e m e xa m i n a t i o n o f
G e m ma S a n t o s a n d t o a t t e s t t o t h e ve r a c i t y o f h e r
f i n d i n g s i n t h e autopsy report.
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TRIAL DATE
Specifically all day of the month, with the regular
appearance of the undersigned city prosecutors before this
Honorable Court.
RESPECTFULLY SUBMITTED.
Pasay City, Philippines, January 3, 2018.
PASAY CITY PROSECUTOR’S OFFICE
Rodrigo Roa’s Hall of Justice
F.B. Harrison Drive, Pasay
City
By:
PAUL RYAN QUIOGUE
Assistant City Prosecutor
Roll No. 67890 / 5-2-07
IBP. No. 667899 / 12-29-07
MCLE Exempt
PTR Exempt
And
LIEZL BARQUILLA
Assistant City Prosecutor
Roll No. 67891 / 5-2-07
IBP No. 667900 / 12-29-07
MCLE Exempt
PTR Exempt
Copy furnished:
ATTY. JOY BALLOVAR
Counsel for the Defense
Room 200, New Valentine Bldg.
Central Philippine University
Lopez Jaena St., Jaro, Iloilo City
Received by:___________
Date: ___________
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