JOHN BON DARELLE BUGAN

BS CRIM 2B
NON-INSTITUTIONAL CORECTION

sample of Pretrial Brief for the prosecution For Later

Republic of the PhilippinesSixth Judicial Region

REGIONAL TRIAL COURT

Branch___Iloilo City

PEOPLE OF THE PHILIPPINES,

CRIMINAL CASE NO._______Plaintiff,FOR:ROBBERY WITH HOMICIDE- versus -

TITO CRUZ AND VIC CRUZ,

Accused.x-----------------------------------------------x

PRE-TRIAL BRIEF OF THE PROSECUTIONTHE PEOPLE OF THE PHILIPPINES,

through the undersigned CityProsecutor, before this Honorable Court, most

respectfully submit this Pre-TrialBrief:

SUMMARY OF ADMITTED FACTS AND PROPOSED STIPULATION OF FACTS

The following are the admitted facts:1. the identities of those charged in the
information and that of thepersons arraigned are one and the same;2. the
identity of Joey Cruz, the victim;3. the killing of the victim;4. the date and places
of the commission of the crime.

EVIDENCE FOR MARKINGS

1. Affidavit of the cashier Geraldine DemetriPurpose: to prove that she was on-
duty when the robbery took place and thatone of the accused pointed a gun at
her, who eventually declared hold-up whilethe other emptied the cash registers
and took some grocery stuffs;2. Affidavit of customer Bea RoblesPurpose: to
prove that she was one of the customers at the time the robberytook place and
JOHN BON DARELLE BUGAN
BS CRIM 2B
NON-INSTITUTIONAL CORECTION

that she saw and identified the accused by their faces;3. Affidavit of customer
Paris MichaelsPurpose: to corroborate the testimonies of Geraldine Demetri and
Bea Robles;3. Autopsy Report of Joey Cruz issued by Iloilo Mission
HospitalPurpose: to prove the extent of the injury and the cause of death of the
victim;4. Blotter Report of Jaro Police Station (ICP-PP3)Purpose: to prove that the
police authority received a report that a robbery tookplace at Iloilo Supermart,
located at Tabuk Suba, Jaro, Iloilo City.

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5. Affidavit of Romeo V. BenamarcaPurpose: To prove that he personally heard a

gun shot from an abandoned ricemill and actually saw the accused holding a gun
and the dead body of thedeceased which subsequently followed the arrest of the
accused.6. Paraffin test resultPurpose: To prove that accused became positive of
gun powder burns.7. Anatomical SketchPurpose: To prove which part of the
victim’s body was shot and the nature,extent and location of wound

8. Ballistics Test resultPurpose: To prove that the slug recovered from the victim’s
body came from thesame gun which was recovered from the possession of Tito
Cruz.9. Fired Shell10. Three live ammunitions11. .45 caliber pistol

ISSUES
JOHN BON DARELLE BUGAN
BS CRIM 2B
NON-INSTITUTIONAL CORECTION

1.Whether or not the accused committed the crime charged;2.Whether or not

they were guilty thereof.

WITNESSES

1. Geraldine Demetri to testify that a robbery took place;2. Bea Robles to testify
that she was one of the customers of the IloiloSupermart at the time the robbery
took place;3. Paris Michaels to testify that she was one of the customers of
IloiloSupemart at the time the robbery took place.4. Romeo V. Benamarca to
testify that he was the police officer who wentto the scene of the crime and
arrested the accused.5. Dra. Isabel Cenon to testify that she conducted the post
mortemexamination of Joey Cruz and to attest to the veracity of her findings in
theautopsy report.6. Police Senior Inspector Anthony Villar to testify that he
conducted theballistics examination and to attest to the veracity of his findings in
the saidreport.7. Chemist Dionisia Paqui to testify that she conducted a paraffin
test tothe accused and to attest to the veracity of her findings in the said report.

T RIAL DATES

Specifically all Fridays of the month, with the regular appearance of

theundersigned city prosecutors before this Honorable Court.

RESPECTFULLY SUBMITTED.

Iloilo City, Iloilo, Philippines, July 4, 2008.

ILOILO CITY PROSECUTOR’S OFFICE

Ramon Q. Avanceña Hall of JusticeBonifacio Drive,Iloilo City

By:

JOHN FRED C. HALLARES

JOHN BON DARELLE BUGAN
BS CRIM 2B
NON-INSTITUTIONAL CORECTION

Assistant City ProsecutorRoll No. 67890 / 5-2-07IBP. No. 667899 / 12-29-07MCLE

ExemptPTR Exempt

And

JASIE ANN MAGHOPOY

Assistant City ProsecutorRoll No. 67891 / 5-2-07IBP No. 667900 / 12-29-07MCLE

ExemptPTR Exempt

Copy furnished:

ATTY. KENETH P. TUPAS

Counsel for the DefenseRoom 200, New Valentine Bldg.Central Philippine

UniversityLopez Jaena St., Jaro, Iloilo CityReceived by:___________Date:
___________

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BS CRIM 2B
NON-INSTITUTIONAL CORECTION

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BS CRIM 2B
NON-INSTITUTIONAL CORECTION

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BS CRIM 2B
NON-INSTITUTIONAL CORECTION

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