REPUBLIC OF THE PHILIPPINES REGIONAL TRIAL COURT LUCENA CITY BRANCH___________

PEOPLE OF THE PHILIPPINES Plaintiff -versus-

CRIMINAL CASE NO.____ (NPS Docket No._______) -for-

ROBBERY ATTY. SIR CHIEF, JINGGOY, JUAN AND JOAQUIN Accused

x----------------------------------------------------------------------------------------------------------------------------x PRE-TRIAL BRIEF OF THE PROSECUTION THE PEOPLE OF THE PHILIPPINES, through the undersigned City Prosecutor, before this Honorable Court, most respectfully submit this Pre trial Brief 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 the persons arraigned are one and the same; 2. The identity of Maya, the victim; 3. The date, and place of the commission of the crime; 4. The robbery was committed by means of conspiracy; 5. The recovery of the 10 trays of jewelry allegedly owned by Maya, the victim; 6. The recovery of the walkie-talkies used by Atty.Sir Chief ,Jinggoy, and Juan; 7. Walkie-talkie of Emerson Calatrava which he surrendered voluntarily.

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EVIDENCE FOR MARKINGS

1. Police Blotter Report of SPO1 Rommel Alday Purpose: To prove that the police authority received a report that a robbery took place at the residence of Maya situated at Lucena City. 2. Affidavit of Emerson Calatrava, Mayas neighbor. Purpose: To describe the scene of the crime the next day that it was discovered and describe the conversation he intercepted in his walkie talkie. 3. Affidavit of CCTV Operator Ricardo Oabel Purpose: To prove that the video footage is authentic. 4. 10 trays of jewelries recovered Purpose: To prove that the recovered jewelries are of the same kind belonging to the victim, Maya. 5. CCTV Video Footage Purpose: To prove that the suspects are indeed the same persons caught in the video footage at the scene of the crime 6. Walkie Talkies recovered from Sir Chief, Jinggoy, Juan and Joaquin Purpose: To prove it was used to command the execution of the crime. 7. Walkie-Talkie of Emerson Calatrava Purpose: To prove to the identity and conspiracy of Atty. Sir Chief, Joaquin, Jinggoy and Juan in committing the crime

ISSUES

1. Whether or not the accused committed the crime charged; 2. Whether or not they were guilty thereof.

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WITNESSES

1.) Police Senior Inspector Rommel Alday - to testify that he had received a report of robbery at the residence of Maya. 2.) CCTV Operator Ricardo Oabel to testify that the video footage was genuine and to identify the suspects are the same persons caught on camera.

3.) Emerson Calatrava- to testify that he saw body of Maya the next day the crime was committed and to testify to the truth of the conspiracy because he intercepted a signal from his own walkie talkie the conversation of Atty. Sir Chief, Jinggoy, Juan and Joaquin

TRIAL DATES

Specifically all Mondays of the month, with regular appearance of the undersigned City Prosecutors before this Honorable Court.

RESPECTFULLY SUBMITTED. Lucena City, Philippines, January 13, 2014

LUCENA CITY PROSECUTORSS OFFICE BY: ATTY.ALBERT I. VILLANUEVA Assistant City Prosecutor And ATTY. ALBERT A. MARQUEZ Assistant City Prosecutor

ATTY.ARJAY ALFPED SALAMILLAS City Prosecutor

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Cc: ATTY.DENNIS RAMIREZ ATTY.EDELYN AYANGCO ATTY.JOHN MARK SAPORNA Counsels for the Defense

Received by:____________ Date: _________________

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