Dioscoro

RELATIONSHIP

How are you related to the PC Ms. Lorigene Lopez?

Do you have a close relationship with the private complainant?

Do you C and A that as a close relative of the PC, you aware of any complaints
filed by the PC in relation to the subject area?

Has the PC visited the subject area prior to the alleged incident leading to this
criminal case?

Have you accompanied her during such visits?

Does she constantly visit the area prior to the alleged incident?

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ALLEGATION THAT THE AREA IS IN SAN LUIS

How long have you been a resident of San Luis?

And as a long-time resident of San Luis you know for certain all the sitios
belonging to the Brgy San Luis correct?

Do you C and A that Sitio Kalipay, Mabuhay, Patak, Bagyangon, are all located
in Brgy. San Luis?

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THE SURVEY

You have knowledge of the areas designated to each of the accused ISF Holders
correct?

Do you C and A that you were present during the court mandated survey
conducted last December 1, 2022?

You were one of the people who accompanied the geodetic engineer during the
court mandate survey conducted on December 1, 2022, correct?

Do you also C and A that, of all the areas allotted to the accused who are
parties to the “kasabutan”, only Ernesto Dagpong’s area was fenced with
barbed wire along its boundaries?

Do have knowledge of a hut which was built outside the area of dagpong?
(Proceed to initial survey if No)
Are you also aware that the men of Mrs. Lopez filed a complaint before the
Barangay Captain of Siloo, alleging that some of the accused pushed the hut
downhill?
What was the purpose of that hut?

______________________________________________________________________
THE INTIAL SURVEY

Do you confirm and affirm that there was also an initial survey on the subject
area conducted on December 9, 2021?
A GPS Sketch map was made as a result of the initial survey correct?

Do you also confirm and affirm that the said GPS sketch map was used as
basis during the court mandated survey to provide the technical description of
the areas allotted to the accused, who are parties to the kasabutan?

Do you confirm and affirm that the barbed wire fence around the area of
Dagpong was built in accordance to the GPS sketch map?

Is it also correct that the fence around dagpong’s area was built to segregate
the area of Lorigene from the area of the accused ISF holders?

Do you confirm and affirm that the “kasabutan” was also based on the GPS
sketch map?

You were a signatory to the kasabutan correct?

ALLEGED PRIOR POSSESSION

When did Mrs. Lopez begin occupying the area subject of the “kasabutan”?

Prior to the alleged incident which led to this case, was she able plant crops or
build improvements in the subject area?

Was she able to do the same in the areas currently occupied by the accused
ISF-holders?

She owns the subject area correct?

Has she filed any action before the proper court to oust the accused from the
area they are occupying, prior to the incident which led to this criminal case?

THE INCIDENT

On November 3, 2021, you accompanied the private complainant to the subject

area to protect her correct? Did you bring anything with you to protect her?

What mode of transportation did you use to go to the subject area?

(What type of vehicle was it? Color? Plate Number?)
(Where did you park?)

Do you C and A that all of the accused were present in the area where the
alleged incident occurred?

From your initial location going to the place of the alleged incident, was the
path an uphill or downhill slope?

Did the incident occur in Dagpong’s area? Lordiso’s area? Ching’s? Cabisay’s?

When you arrived in the area where the alleged incident happened, were all the
accused spread out or were they gathered in one area?

All of the accused were within your group’s view correct?

Was your group facing the same direction when you saw all the accused?

Were all the accused far away from where you were standing?
(If No) who was close to your position at that time? Is his/her distance within
the range of this courtroom?

You alleged that accused built a fence and intruded into the PC’s area, where
was this fence built? Was it somewhere in the area now allotted to Dagpong,
Lanta, Ching or Cabisay’s area based on the Kasabutan?

What was the fence made out of?

(Ask if he was present during the survey) was the fence still present during the
survey? If No, do you know what happened to it?

When your group arrived, were all accused building the fence?

(If answer is no) Who among the accused were building a fence when you
arrived?
Could you point them out? Can you name them?

Were they building the fence on one side of the area? Or were the accused
spread out working on different sides?
Who was working on the right side? left? upper part? Lower part?

(If not all was building) What were the other accused doing?

Were they all carrying bladed weapons when you first saw them? Who did you
specifically remember bringing a bladed weapon? Can you name the accused?
What type of bladed weapon was it? Was it sheathed at that time?

Did all the accused immediately notice your group’s presence when you
arrived?

Who among the accused did you first notice when you arrived? What was he
doing? point him out if he is in this courtroom

Who among the accused first noticed your group’s arrival?(if he cannot recall
move to *)
What was he doing prior to noticing your group’s presence?
What was his reaction when he noticed your group?
Did he/she have a bladed weapon with him/her?
Was he/she already wielding it when you saw him/her?

*Did they approach your group when they noticed you? Did all the accused
notice your group all at once? Did they surround you or did they gather in
front of your group? Where they close to each other when they gathered?

As they were approaching your group, were they walking? Who among the
accused did you specifically remember walking towards your group? (if he
cannot recall, move to *) Was he silent while walking? Was he angry? Was he
carrying a blade weapon?

*Were they all carrying bladed weapons they approached your group and
gathered in front of you?
Were the weapons sheathed?
Who among the accused did you specifically remember carrying a weapon?
What weapon was it?
While they were approaching, were they already aggressive based on their facial
expressions? Were they silent as they were walking towards your group?

Did you feel like your group was already in danger at that time?
So, you feared for your safety?

After they approached you and gathered in front of your group, was this the
time Mrs. Lopez addressed to all the accused that the area belongs to her and
that she is in prior possession and occupation of the subject area?

(If No) When did she address to all the accused that the area is belongs to her?
Did she shout when she made the declaration?

When she made the declaration, were you surrounded by the accused or were
they gathered in one area?

Were they positioned in the path towards the location of your parked vehicle?

After Mrs. Lopez made such a declaration, did it further amplify the fear that
you already felt?

When all the accused, as a response, made the life-threatening utterance

“basin mouli mo nga duguan pag mubalik mo” and “kinumo ug atay ra amo
gusto”, do you C and A that after such utterance, you were already overcome
by uncontrollable fear?

Who did you specifically remember made such utterance?

What about your group, what was their demeanor? Did it look like they were
also overwhelmed by uncontrollable fear?

(If witness says they made the threat in unison, but different utterances) Are
you saying they threatened the accused at the same time, but they uttered
different threats? Who made the specific utterance then?
(If they did not make the threat in unison) so they threatened ms Lopez one by
one? There are 21 accused in this case, who made the specific life-threatening
utterance you alleged in your affidavit?

What were they doing with their weapons while they were threatening Ms.
Lopez?

Did you run after all the accused made the life-threatening utterance?

Did you sustain injuries while walking/running away?

What were all the accused doing when you were leaving?

Were you the one who identified all of the accused when you reported to the
police?

You claim to know all of the accused. Can you name all of them?
As a long time resident of San Luis, who among them is from barangay San
Luis?

Can you point to one accused in this courtroom that you specifically identified
before the police?
What is his/her name?
That would be all for the accused YH