Proposed Flow of Stipulation for the Arraignment and Pre-Trial – PRACTICE COURT I

If Accused Pleads to a Lesser Offense If Accused Pleads Not Guilty

1. May we know from the accused, Your Honor, if he is willing to admit that he is the same person
charged in the information?
It is with fervor, Your Honor, that the petitioner Considering that the accused has pleaded Not
believes through this representation that it will be Guilty to the charge, may we ask the Honorable
true injustice to reduce the charge to a lesser Court to allow the prosecution to stipulate the
crime. Considering the burden of proof that we facts relevant to the expeditious resolution of this
shall be proving in the course of litigation, it will trial.
amount to no less than murder. Therefore, Your
Honor, the prosecution denies the plea of the
accused and that the Honorable Court may allow
us to lay down further pieces of evidence which
shall warrant the conviction of the accused.
2. May we know from the accused, Your Honor, if he is willing to stipulate that he is employed as a
security guard stationed at 7-11 Masangkay Branch in Sta. Cruz?
3. Same request, Your Honor, that the accused is on duty from 7pm to 7am? (This is to establish the
fact that the accused was allegedly on duty at the time of the crime.)
4. Same request, Your Honor, that the victim is personally known to the accused (since the former
had been the usual delivery personnel to the store)?
5. Same request, Your Honor, that there was antipathy between you and the victim (a long standing
animosity since you were not in favor with the way the victim delivered to the store)?
6. Same request, Your Honor, that the accused personally shot the victim
7. Same request, Your Honor, that the accused encountered Rogelio Sapiendante before fleeing the
scene of the crime and before his tour of duty ended? – SHOULD HE DENY FLEEING THE CRIME
SCENE - Same request, Your Honor, that the accused never returned to his designated post.
8. Same request, Your Honor, that the accused was the same person apprehended by Barangay
Chairman Aluroy and P/O Omli?
9. Same request, Your Honor, that a .38-calibre firearm was recovered from your person upon your
apprehension?
10. Same request, Your Honor, that the said .38-calibre firearm was the same service firearm issued
by the Company for use in the course of your duty only?
11. Same request, Your Honor, that the same firearm was turned over by the apprehending officer to
the ballistic expert for scrutiny.
12. Same request, Your Honor, that the victim is the same subject of the medico-legal report
prepared by Dr. Voltaire Nulud?