Republic of the Philippines

First Judicial Region

REGIONAL TRIAL COURT
BRANCH 8
La Trinidad, Benguet

PEOPLE OF THE PHILIPPINES,

Complainant,

For: Carnapping
Criminal Case No. 15-CR-10935

-versus-

CLIFFORD B. GABOY,
JANVIER S. SAGUID,
Respondents,

x-----------------------------------------------------------------------------------------------------------------x

PRE TRIAL BRIEF

FOR THE PROSECUTION

The undersigned Private Prosecutor, with the conformity of the Public Prosecutor, and
unto this Honorable Court, respectfully submits this Pre Trial Brief and for that purpose alleges
that:

SUMMARY OF ADMITTED FACTS

1. The identities of those charged in the information and that of thepersons arraigned are

one and the same;

2. The date and places of the commission of the crime;

PROPOSALS FOR STIPULATION

1. That the Respondents are employees of the JEWEL IGOROT BUILDING

MANAGEMENT;

ISSUES

1. Whether the Respondents are guilty of the crime as charged;

WITNESSES

1. Bonner S. Batanes
2. Security Guard Adrian A. Lopez of MG Knight Investigation and Detection Agency
3. PO1 Froilan Gabriel
4. One other witness to testify on the taking of the vehicle.

People v. Gaboy and Saguid

Pre-Trial Brief
Page 1 of 2
 DOCUMENTARY EVIDENCE
1. Special Power of Attorney issued in favour of BONNER S. BATANES as Exhibit
“A”
2. Copy of Logbook entries made by A. Lopez as Exhibit “B”
3. Police Report made by PO1 Froilan Gabriel of the La Trinidad MPS as Exhibit “C”
4. Photographs of Damage to vehicle as Exhibit “D”
5. Promissory Note of Janvier Saguid as Exhibit “E”
6. Promissory note of Clifford b. Gaboy as Exhibit “E-1”
7. Motor Claim Computation Sheet as Exhibit “E”
8. Receipts of amounts paid for the repair as Exhibit “F”
TRIAL DATES

Prosecution needs at least Five (5) dates to complete the presentation of his evidence-in-
chief.

Respectfully submitted.

Baguio City, Philippines, February 22, 2016.

Pros. ALIPIO GEORGE BAYUBAY Jr.

Attending Prosecutor
Office of the Provincial Prosecutor

BRENNER L. BENGWAYAN
Private Prosecutor
Room 406, 4 Floor Lyman Ogilby Building
th

No. 358 Magsaysay Avenue, Baguio City

Roll No.61403, March 27, 2012
IBP Lifetime No. 0980760; 1-28-15 Baguio-Benguet Chapter
PTR. No. 2446116; 1-4-16
MCLE Compliance No. V-0000119; 6-20-2013
Mobile No. 09217335999
(074) 422 4286
Cc:

Atty. MAYCHELLE S. ABLOG

Public Attorneys Office
Justice Hill, La Trinidad Benguet

People v. Gaboy and Saguid

Pre-Trial Brief
Page 2 of 2