Script for Direct Examination of SECURITY

GUARD

Q1. Do you swear to tell the truth and nothing but the truth?
A1. I do, ma’am.

Q2. Are you aware that you may face criminal liability for false
testimony or perjury if you will not tell the truth?
A2. I am, ma’am.

Q3. Please state your name, age, address and occupation.

A3. I am Jerry T. Tiu, 27 years old, residing at Barangay
Washington, Surigao City, security guard of Avanza Resto
Bar at Borromeo St., Brgy Taft, Surigao City, Philippines.

Q4. Do you know the accused in this instant case, Mr. Virgil
Sollozzo?
A4. Yes, ma’am.

Q5. Why do you know him?

A5. He is one of the customers of Avanza Resto Bar on the 2nd
day of August 2014.

Q6. Where were you on the night of August 2, 2014?

A6. I was in Abanza’s Resto Bar of Borromeo St., Brgy Taft,
Surigao City, Philippines.

Q7. Why were at Abanza’s Resto bar on August 2, 2014?

A7. I was there because I am working as Security Guard of the
establishment and it was my shift duty during that night.
Q8. You said you know the accused in this case, how do you
know that he is one of the customers on that night?
A8. Because it was my shift duty on the night of August 2, 2014.
And I saw Mr. Virgil Sollozzo with a companion.

Q9. How do you know that he is one of the customers?

A9. Because it was my shift duty on the night of August 2, 2014.
And I saw Mr. Virgil Sollozzo with a companion.

Q10.Who else did you see during that night?

A10. I also saw the victim and his companions.

Q11.Why do say that the accused and his companion and the
victim and his companions are some of your customers?
A11. I am sure because it is my duty to put a stamp on every
customer’s wrists in order to know if he paid an entrance fee
and identify if he one of the customers.

Q12.During your shift, did you observe something unusual all

through-out your shift?
A12. Yes, ma’am.

Q13.What did you observe then, during that night?

A13. I saw a commotion just a few meters away from my post.

Q14.Can you tell this court, what commotion exactly did you see?
A14. I saw Mr. Virgil Sollozo and Mr. Peter Clemencia having a
talk, thereafter one of them shouted.

Q15.Who between the two men did you hear shouting?

A15. It was Mr. Peter Clemencia the victim, ma’am.
Q16.How do you know that it was the victim who shouted?
A16. The place was well lighted, that I could see them clearly near
from my post.

Q17.And what was the victim shouting?

A17. I heard the victim shouted “Kay uman kung tag-bastos, mu
awai kaw?”.

Q18.After the victim shouted those words, what happened next?

A18. The victim mounted his motorcycle and started to switch the
ignition.

Q19.After switching the ignition, what happened next?

A19. Mr. Virgil Sollozzo tried to stop the victim from going by
blocking him, spreading his arms in front of the motorcycle.

Q20.What did the victim do after Mr. Virgillo Sollozo blocked the
latter from going?
A20. Mr. Virgillo Sollozo was bumped by Mr. Peter’s motorcycle
because the latter, without hesitation switched gear and
suddenly pull down the throttle of the motorcycle causing Mr.
Virgil to fell down.

Q21.The moment Mr. Virgil fell down, what happened next?

A21. Mr. Peter pulled over to stop as he was approaching to Mr.
Virgil and I saw that he took a knife out from his pocket.

Q22.How do you know that it was a knife?

A22. I was approximately 10 meters away from the incident and
the vicinity as I said earlier, was well lighted that is why I can
clearly saw that it was a knife.
Q23.What else happened, if any, after the victim pulled a knife
from his pocket?
A23. I heard the accused’s companion shouting in a loud voice
“Pre pag-bantay kay jaoy ija kutsilyo!”.

Q24.What did you witness next, if any?

A24. While Mr. Virgil was trying to get up and saw the victim
approaching, the victim tried to land a stabbing blow to Mr.
Virgil but to no avail.

Q25.Why do you say so?

A25. Mr. Virgil manage to grapple for the possession of the knife
wielded by the victim, the latter was stabbed as a result.

Q26.So, Mr. Virgil was not at fault in this case.

A26. Yes, ma’am.

Q27.This happened in the early hours of August 3, 2014?

A27. Yes ma’am.

Q28.What else did you see?

A28. I saw blood both from the victim and Mr. Virgil Sollozo,
ma’am.

Q29.I have no further questions. Do you have anything to add or

retract, Mr. Witness?
A29. None, ma’am.

Q30.Are you willing to sign your statement?

A30. Yes, ma’am.