Cross Examination Questions

CONFIDENTIAL INFORMANT

1. Mr. Officer, you claimed that in the morning of June 7, 2015, your office received a report
regarding the alleged peddling of illegal drugs of the accused, correct?
2. And this information came from a confidential informant, correct?
3. These confidential informant is an asset of your station, correct?
4. And according this police asset of yours, the accused had allegedly ordered from the
accused P1,000.00 worth of shabu, am I right?
5. So the confidential informant was the one who made the offer to buy shabu from the
accused, correct?
6. So you just merely relied on this information given by a third person?
7. You did not bother to verify this information?
8. Now, Mr. Officer, isn’t it that when someone comes to your office or spot report about
what transpired between you and your Confidential Informant, correct?
9. And there was no compliance to this, am I right?
10. You are a police officer, correct?
11. And as a police officer, you were trained to follow protocol, correct?
12. But this simple procedure, you failed to do so, am I right?
13. Isn’t it Mr. Officer, that you are required to conduct proper and adequate planning and
preparation before conducting a buy-bust, am I right?
14. Would you agree that one of the crucial elements of the planning is the preparation of
the buy-bust money?
15. And as a police officer, it is safe to assume that you are familiar with the PNP Manual on
Anti-Illegal Drugs Operation and Investigation, am I right?
16. Isn’t it that in your PNP Manual on Anti-Illegal Drugs Operation and Investigation, the buy
bust money should be dusted with ultra-violet powder by the PDEA Laboratory Service or
the PNP Crime Laboratory?
17. But this was not again complied with in this case, correct?

CCTV FOOTAGE

18. You also mentioned that the CI came with you at Pichay Lodging House, the alleged place
of transaction, am I correct?
19. And that this confidential informant was the one who introduced you to the accused, am
I right?
20. Mr. Officer, are you aware that prior to the issuance of a business permit, establishments
are required to install CCTV cameras pursuant to City Ordinance No. 2009-019?
21. Are you aware that the PNP is tasked to supervise the implementation of this ordinance
by identifying the specifications and location of these CCTV Cameras?
22. Are you aware that the PNP is authorized to secure CCTV footage in connection with
alleged criminal activities, Mr. Officer?
23. Considering that Pichay Lodging House is a hotel establishment, would you agree that it
has CCTV cameras installed pursuant to CO No. 2009-019?
24. Would you agree that a footage capturing that specific date and time would have been
vital to prove that you were at Pichay Lodging House with the confidential informant, am
I correct?
25. Yet, you did not secure any footage in order to justify your claim, am I right?
26. And for security purposes, the confidential informant cannot testify to corroborate your
claims, am I correct?
27. So aside from your allegations, there is nothing else to prove that you were with the
confidential informant, correct?
28. And aside from your allegations, there is nothing else to prove that there was the sale of
illegal drugs, correct?
Arrival of the Barangay Kagawad

29. Mr. Officer, in your previous testimony, you mentioned that you conducted the inventory
of the alleged seized items at the Laoag City Police Station, am I right?
30. And you took pictures of these seized items, correct?
31. And this was before the arrival of the barangay officials, correct?
32. And it took you 30 minutes to wait for the barangay officials, am I right Mr. Officer?
33. So you are now saying that the inventory and photographing is not immediate because
you still have to wait for 30 minutes for the barangay official to arrive, am I correct?
34. And that when this barangay official already arrived 30 minutes later, all that he was made
to do is to sign the inventory, correct?
35. Mr. Officer, during that time of waiting, the accused was closely guarded, am I correct?
36. And that aside from members of your team, there were also other members of the Police
Station at that time, am I right?
37. Would you agree with me then at that time, the accused was out-numbered by your team
and also the other members of the police station who are fully armed, am I correct?
38. By the way, were did you put the items allegedly confiscated, Mr. Officer?
39. So this items were laid out on a table?
40. Such that anytime, any member of your team can freely inspect the same, am I correct?
41. So, there is a possibility of movements or alteration of the evidence seized, am I correct
Mr. Officer?

CERTIFICATE OF INVENTORY

42. Mr. Witness, during your testimony, you mentioned that you prepared a Certificate of
Inventory, correct? (YES)
43. And contained in that Certificate of Inventory are the items you allegedly seized from the
accused, correct? (YES)
44. And there was only one witness who signed the Certificate, correct?
45. There was no DOJ representative who signed the Certificate correct?
46. Likewise, it was not signed by any representative of the media, correct?
47. Such that when you prepared this inventory, there were no representatives of the media
or the DOJ correct?
48. So there was no compliance with the mandatory three-witness rule under Section 21 of
R.A. 9165, correct?

*Note: Fiscal will try to ask “WHY” on re-direct

Re-cross: (Call-Log)

1. You mentioned that you tried to call this media personality and DOJ representative, what
did you use in calling these witnesses?
2. But you did not submit a call-log as part of your evidence to justify that indeed you made
calls to representatives of the media and the DOJ?
3. The truth is, you did not make any calls at all, am I right?
4. Because if you did, then you should have printed a call log and submitted the same as
part of your evidence am I correct?
5. But there is no such document that you submitted, am I correct?