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Republic of the Philippines

National Capital Judicial Region


Regional Trial Court
Branch 1, Pasay City

PEOPLE OF THE
PHILIPPINES
Plaintiff,

- versus - CRIMINAL CASE NO. 001-2015


For: Kidnapping with Murder
ALVAN OLIVEROS
Accused,
x----------------------------------------x

PRE-TRIAL BRIEF OF THE PROSECUTION

COMES NOW, the Plaintiff, through the undersigned counsel, before


this Honorable Court, most respectfully submit this Pre-Trial Brief in
compliance with the Court’s order on January 7, 2015, containing the
following:

1. The Prosecution is not willing to enter into an amicable settlement of


the case; There is likewise no plea bargaining agreement entered into;

2. Plaintiff admits the following facts:


2.1 The personal circumstance of the parties in the counter-
affdiavit;

3. The Prosecution intends to present the following documents, in


connection with which the prosecution requests from the accused his
admission of their execution and due authenticity:
3.1 Exhibit A – Marriage contract of Roselyn Barrientos and the
victim Sadam Prudenciano.
3.2 Exhibit B – Affidavit of complainant Roselyn Barrientos
3.3 Exhibit C – Affidavit of witness Kevin Dela Cruz
3.2.1 Exhibit B.1 – the name and signature of Kevin Dela
Cruz.
3.3 Exhibit D – Affidavit of witness Maureen Patajo
3.3.1 Exhibit C.1 – the name and signature of Maureen Patajo.
3.4 Exhibit E – Death Certificate of the victim.
3.5 Exhibit F – Medical Autopsy Report of the victim.
3.6 Exhibit G – PostMortem Dental Record of the victim.
3.7 Exhibit H – .45Caliber Gun obtained in the possession of the
accused during his arrest.
3.8 Exhibit I – One Million Pesos ransom money obtained in the
possession of the accused during his arrest.
3.9 Exhibit J – Photo taken where the body of the victim was
found.

4. Issue to be tried:
4.1 Whether or not the accused committed the crime charged
against him;
4.2 Whether or not the accused was validly arrested;

5. The prosecution intends to present the following witness:


5.1 Rosely Barrientos, wife of the victim
5.2 Kevin Dela Cruz, eye witness
5.3 Maureen Patajo, eye witness
5.4 Jal Disomimba, arresting police inspector
5.5 Dr. Judy Anne Yulo, medico legal

WHEREFORE, prosecution prays that the foregoing be taken in


cognizance of.

City of Pasay, February 8, 2015

Edward Confiado Santiago


Assistant City Prosecutor

Copy furnished:

Rich Almario
Counsel of the defense
123 Ayala Ave., Makati City