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Republic of the Philippines REGIONAL TRIAL COURT Lucena City BRANCH_______

PEOPLE OF THE PHILIPPINES, PHILIPPINES Plaintiff -versus-

CRIMINAL CASE NO.________ (NPS Docket No. _____________) -for-

HONESTO ROBBERY WITH HOMICIDE Lucena City Accused. x----------------------------------------------------------------------------------------------------x PRE-TRIAL BRIEF OF THE PROSECUTION THE PEOPLE OF THE PHILIPPINES, t h r o u g h t h e u n d e r s i g n e d C i t y 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 identity of the one w h o s e c h a r g e d i n t h e i n f o r m a t i o n a n d t h a t o f t h e person arraigned are one and the same; 2. the identity of Maya, the victim 3. the date and places of the commission of the crime. 4. the robbery committed 5.the killing of the victim on the occasion of robbery 6. the existence of the CCTV footage of the commission of crime. 7. the recovery of ten (10) trays of jewelry. 8. the recovery of baseball bat. EVIDENCE FOR MARKINGS 1. Police Report of Rodel Alday of Lucena City Police District Purpose: to prove that the police authority received a report that a robbery took place and the killing of the victim Maya in her residence situated at Lucena City 2. Affidavit of CCTV Operator Ricardo Oabel. Purpose: to prove the existence and authenticate and attest to the genuine of the recorded video footage caught by the CCTV camera during the actual scene of the crime. 3. Affidavit of Jinggoy, Purpose: to testify that he heard a loud scream by the victim, when they are in the house of Maya. 4. Affidavit of Juan. Purpose: to testify that Honesto was there at the scene of the crime holding a bloodied baseball bat. 5. Affidavit of Joaquin Purpose: to corroborate for the testimonies of Jinggoy and Juan 6. Autopsy Report of Maya issued by Lucena City Memorial Hospital. Purpose: to prove the extent of the injury and the cause of death of the victim;

7. Anatomical Sketch Purpose: To prove which part of the victims head was hit and the n a t u r e , extent and location of wound. 8. Baseball Bat 9. Ten (10) trays of jewelry bags. ISSUES 1. Whether or not the accused committed the crime charged; 2. Whether or not he was guilty thereof. WITNESSES 1. Rodel Alday to testify that he was the police officer who went to the scene of the crime to investigate. 2. Ricardo Oabel to testify the existence of the CCTV video footage and its content. 3. Jinggoy, to testify that the killing of the victim was committed by Honesto. 4. Juan to testify that he see Honesto holding a bloodied bat near the bloodied victim. 5. Joaquin to testify that he was with Jinggoy and Joaquin when the killing of the victim was committed. 6. Dra. _________ to testify that she conducted the post m o r t e m examination of MAYA and to attest to the veracity of her f i n d i n g s i n t h e autopsy report. TRIAL DATES Specifically all Fridays of the month, with the regular appearance of the undersigned city prosecutors before this Honorable Court RESPECTFULLY SUBMITTED. Lucena City, Quezon, Philippines, January 12, 2014. LUCENA CITY PROSECUTORS OFFICE By: ATTY. ALBERT I. VILLANUEVA Assistant City Prosecutor And ATTY. ARJAY ALFPED SALAMILLAS Assistant City Prosecutor ATTY. ALBERT A. MARQUEZ City Prosecutor Copy furnished: ATTY. DENNIS RAMIREZ ATTY. EDELYN AYANGCO ATTY. JOHN MARK SAPORNA Counsel for the Defense Received by:_______________ Date: _____________________

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