(Information for Serious Physical Injuries) (caption) INFORMATION The undersigned, _____________, accuses _____________ of the crime of SERIOUS

PHYSICAL INJURIES, committed as follows, to wit: That on or about _____________, at about _________ (a.m./p.m.), in the City/Municipality of _____________, Province of _____________ and within the jurisdiction of this Honorable Court, the said accused did there and then willfully, unlawfully and feloniously, and without justifiable cause therefor, attack, assault, and beat one _____________ with a baseball bat, resulting to injuries to the latter rendering him in capacitated for labor for a period of more than thirty (30) days. Contrary to law. _____________, Philippines, __Date__. PROSECUTOR Witnesses: ____________________ ____________________ (Certification of Preliminary Investigation) ____________________ ____________________

_______ FOR: ROBBERY WITH HOMICIDE TITO CRUZ AND VIC CRUZ. the identities of those charged in the information and that of the persons arraigned are one and the same.versus – Republic of the Philippines Sixth Judicial Region REGIONAL TRIAL COURT Branch___ Iloilo City CRIMINAL CASE NO. 3. . 4. Affidavit of the cashier Geraldine Demetri Purpose: to prove that she was on-duty when the robbery took place and that one of the accused pointed a gun at her. x-----------------------------------------------x PRE-TRIAL BRIEF OF THE PROSECUTION THE PEOPLE OF THE PHILIPPINES. the killing of the victim. the date and places of the commission of the crime. through the undersigned City Prosecutor. before this Honorable Court. 2. 2. Accused. Affidavit of customer Paris Michaels Purpose: to corroborate the testimonies of Geraldine Demetri and Bea Robles. Affidavit of customer Bea Robles 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. . Plaintiff. who eventually declared hold-up while the other emptied the cash registers and took some grocery stuffs. the victim. most respectfully submit this Pre-Trial Brief: SUMMARY OF ADMITTED FACTS AND PROPOSED STIPULATION OF FACTS The following are the admitted facts: 1. Autopsy Report of Joey Cruz issued by Iloilo Mission Hospital Purpose: to prove the extent of the injury and the cause of death of the victim. 3. 3.PEOPLE OF THE PHILIPPINES. EVIDENCE FOR MARKINGS 1. the identity of Joey Cruz.

with the regular appearance of the undersigned city prosecutors before this Honorable Court. Blotter Report of Jaro Police Station (ICP-PP3) Purpose: to prove that the police authority received a report that a robbery took place at Iloilo Supermart.45 caliber pistol I S S U E S 1. Benamarca 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. 9.7. 6. 5. located at Tabuk Suba. Iloilo City. 5. Affidavit of Romeo V. 2. Police Senior Inspector Anthony Villar to testify that he conducted the ballistics examination and to attest to the veracity of his findings in the said report. 4. Whether or not the accused committed the crime charged. . Fired Shell 10. Three live ammunitions 11. T RIAL DATES Specifically all Fridays of the month. Geraldine Demetri to testify that a robbery took place. Jaro. Chemist Dionisia Paqui to testify that she conducted a paraffin test to the accused and to attest to the veracity of her findings in the said report. 8. W I T N E S S E S 1. Dra. Benamarca to testify that he was the police officer who went to the scene of the crime and arrested the accused. 6. Romeo V. Anatomical Sketch Purpose: To prove which part of the victim’s body was shot and the nature. Paris Michaels to testify that she was one of the customers of Iloilo Supemart at the time the robbery took place. 7.4. Bea Robles to testify that she was one of the customers of the Iloilo Supermart at the time the robbery took place. Paraffin test result Purpose: To prove that accused became positive of gun powder burns. . 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 Tito Cruz. Whether or not they were guilty thereof. 2. 3. Isabel Cenon 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. extent and location of wound.

RESPECTFULLY SUBMITTED. TUPAS Counsel for the Defense Room 200. 667900 / 12-29-07 MCLE Exempt PTR Exempt Copy furnished: ATTY. New Valentine Bldg. Iloilo City. 2008.Iloilo City By: JOHN FRED C. Central Philippine University Lopez Jaena St. No. 67890 / 5-2-07 IBP. Avanceña Hall of Justice Bonifacio Drive. ILOILO CITY PROSECUTOR’S OFFICE Ramon Q. July 4. Iloilo. 67891 / 5-2-07 IBP No. KENETH P. Iloilo City Received by:___________ Date: ___________ . Jaro. Philippines. 667899 / 12-29-07 MCLE Exempt PTR Exempt And JASIE ANN MAGHOPOY Assistant City Prosecutor Roll No. HALLARES Assistant City Prosecutor Roll No..

Iloilo City. Plaintiff. through the undersigned counsel. EVIDENCE FOR MARKINGS 1. M. 3. Gabriel Salas Purpose: to prove that he admits the killing of the victim but the same was done in self-defense. .versus – GABRIEL SALAS. the identity of Sulpicio Treyes. x-----------------------------------------------x PRE-TRIAL BRIEF OF THE ACCUSED ACCUSED. Affidavit of accused.Republic of the Philippines Sixth Judicial Region REGIONAL TRIAL COURT Branch___ Iloilo City PEOPLE OF THE PHILIPPINES. . the killing of the victim. place and time of the killing. 2. 4. Blotter Report of Molo Police Station (ICP-PP4) Purpose: to prove that the accused Gabriel Salas voluntarily surrendered to the Police authorities. the identities of those charged in the information and that of the CRIMINAL CASE NO. the date.D. 2.. 4. 2008 at about 1:30 in the morning and at Corner Valeria-De Leon Sts. Affidavits of accused. Greg Fajardo and Alfredo Golez Purpose: to prove that they were at the place where the crime was committed but have no participation thereof. Cielo F. AND GREG FAJARDO. Medical Report issued by Dra. Eltonn. 3. the victim. ALFREDO GOLEZ. before this Honorable Court. most respectfully submit this Pre-Trial Brief: SUMMARY OF ADMITTED FACTS AND PROPOSED STIPULATION OF FACTS The accused admit the following: 1. Accused._______ FOR: MURDER persons arraigned are one and the same. which was May 5. to Gabriel Salas Purpose: to prove that the accused sustained several wounds as a result of the aggression by the victim.

GALLEGO Counsel for the Defense Roll No. Cielo F. 69009 / 5-2-07 IBP. 890591 / 12-20-07 PTR no. Jaro. 2. Iloilo City. 789085 / 12-29-07 MCLE Compliance No. June 2. T RIAL DATES Specifically all Fridays of the month. Accused Gabriel Salas to testify on the matters and circumstances attending the killing of the victim. Witness Jason Pilas-Pilas to testify on the exchange of words and blows between the accused Gabriel Salas and the deceased which resulted to the death of the victim. Accused Alfredo Golez and Greg Fajardo to testify on their nonparticipation on the killing. 890590 / 12-20-07 PTR No. 345668 / 01-05-08 . with the regular appearance of the undersigned counsels before this Honorable Court.Whether or not they were guilty thereof. Iloilo City By: RHONALYN C. M..I S S 1. 2. RESPECTFULLY SUBMITTED. 789084 / 12-29-07 MCLE Compliance No.D. SABIDO Counsel for the Defense Roll No. Eltonn. 345667 / 01-05-08 And EVANGELINE S. Philippines. No. U E S W I T N E 1. to testify on the veracity of the findings stated in the medical report of Gabriel Salas. Dra. S S E S 3.Whether or not the accused committed the crime charged. 2008 GALLEGO-SABIDO LAW OFFICES Arguelles St. 4. 68999 / 5-2-07 IBP. No. Iloilo.

REGUETA Assistant City Prosecutor Ramon Q. SHYR PHOEBE F.Copy furnished: PROS. Avanceña Hall of Justice Bonifacio Drive. Iloilo City Received by:___________ Date: ___________ .

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