Republic of the Philippines

REGIONAL TRIAL COURT

FIRST JUDICIAL REGION
Branch 111
Baguio City

THE PEOPLE OF THE PHILIPPINES,

Plaintiff, CRIM CASE NO. 22222-R

-versus- For:

RAYMUNDO A. ABNOYUN, Rape with Homicide

Accused.

TRIAL BRIEF
(For the Prosecution)


I. STATEMENT OF THE CASE

This is case for murder filed against the accused Padilla Y.
Valeriano, perpetrated on the night of March 20, 1996, against the
helpless victim on her way home from work.

II. PLEADINGS
A. Information
The incident happened at Pico, La Trinidad, Benguet at the
Trading Post area within the jurisdiction of this Honorable
Court of Regional Trial Court, Branch 23, La Trinidad,
Benguet.

B. Answer
The accused merely denied his participation in the crime and
interposed an alibi as his defense
C.
III. MAIN ISSUES

Whether or not there is a proof beyond reasonable doubt that the

accused Padilla Y. Valeriano killed the victim, Angelina Valderaza,
with treachery, evident premeditation and abuse of superior
strength.
IV. FACTS TO BE ESTABLISHED
A. The fact of the death of the victim Angelita Valderaza
B. The victim died as a result of a stab wounds in the chest and
abdomen.

V. EVIDENCE TO BE PRESENTED BY PLAINTIFF

To establish the fact of the death of the victim, the cause of death
and the determination of the type of instrument which might have
been used in the perpetration of the crime.

DIRECT EXAMINATION OF DR. ALMARK B. MARCOS, THE MEDICO-LEGAL

OFFICER WHO EXAMINED THE CADAVER OF THE VICTIM.

Atty: We are offering Dr. Almarck B. Marcos’ testimony, the medico-legal expert
who examined the cadaver of the victim, Angelita M. Valderaza. He will testify as
to the fact of death of the victim and as to the stab wounds and other injuries
found on the body of the victim.

DIRECT EXAMINATION

Preliminary Questions

Q: What is your profession?

A: I am a Medico-Legal Officer

Q: Where do you practice your profession?

A: At the Regional Laboratory Office-Cordillera of the National Police.

Q: How many years have you been occupying this position?

A: Fifteen (15) years.

Q: Where did you finish your medical course?

A: I finished my course at the Saint Louise University, College of Medicine.

Q: And what year did you graduate?

A: 1992.

Q: Did you take the Licensure examination for Doctors?

A: Yes, after a year.

Q: Did you pass the said licensure exam?

A: Yes, I did.

Q: After passing the licensure exam, did you apply to be a Medico-Legal

Officer immediately?
A: No sir. I went into private practice for three(3) years.

2
Q: Can you tell us about your 3-year private practice?
A: I attended to patients with various diseases. I was a general surgeon.

Q: So, after three years, what did you do?

A: I went into a special training to be a medico-legal then applied at the
Regional Crime Laboratory Office-Cordillera of the National Police.

Q: And you were hired, is that correct?

A: Yes.

Q: As a Medico-Legal Officer, what are your duties and functions?

A: It includes conducting autopsy of cadavers to determine different
causes of death, victims of physical injuries, examining of sexual abuse,
exhuming of cadavers and making corresponding report of each
examination.

Q: And how many times have you conducted autopsy of cadavers?

A:
Q:
A: