Republic of the Philippines

REGIONAL TRIAL COURT

Branch 69
Cebu City
PEOPLE OF THE PHILIPPINES,
Plaintiff,

CRIMINAL CASE NO._______

FOR:
ROBBERY WITH HOMICIDE

- versus JOSE TIDORA AND WALLY TINIDORA,

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 Alden Richards, 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 Maine Mendoza
Purpose: to prove that she was on-duty when the robbery took place and that
one of the accused pointed a gun at her, who eventually declared hold-up while
the other emptied the cash registers and took some grocery stuffs;
2. Affidavit of customer Pia Alonzo Wurtzbach
Purpose: to prove that she was one of the customers at the time the robbery
took place and that she saw and identified the accused by their faces;
3. Affidavit of customer Paris Hitler
Purpose: to corroborate the testimonies of Maine Mendoza and Pia Alonzo
Wurtzback;
4. Autopsy Report of Alden Richards issued by Cebu Doctors Hospital
Purpose: to prove the extent of the injury and the cause of death of the victim;
5. Blotter Report of Cebu Police Station (ICP-PP3)

Purpose: to prove that the police authority received a report that a robbery took
place at Cebu Supermart, located at Tabuk Suba, Cebu, Cebu City.
5. Affidavit of Romeo V. Benamarca
Purpose: To prove that he personally heard a gun shot from an abandoned rice
mill and actually saw the accused holding a gun and the dead body of the
deceased which subsequently followed the arrest of the accused.
6. Paraffin test result
Purpose: To prove that accused became positive of gun powder burns.
7. Anatomical Sketch
Purpose: To prove which part of the victims body was shot and the nature,
extent and location of wound.
8. Ballistics Test result
Purpose: To prove that the slug recovered from the victims body came from the
same gun which was recovered from the possession of Jose Tidora.
9. Fired Shell
10. Three live ammunitions
11. .45 caliber pistol
ISSUES
1. Whether or not the accused committed the crime charged;
2. Whether or not they were guilty thereof.
WITNESSES
1. Maine Mendoza to testify that a robbery took place;
2. Pia Alonzo Wurtzbach to testify that she was one of the customers of
the Cebu Supermart at the time the robbery took place;
3. Paris Hitler to testify that she was one of the customers of Iloilo
Supemart at the time the robbery took place.
4. Romeo V. Benamarca to testify that he was the police officer who went
to the scene of the crime and arrested the accused.
5. Dra. Isabel Cenon to testify that she conducted the post mortem
examination of Alden Richards and to attest to the veracity of her findings in the
autopsy report.
6. Police Senior Inspector Anthony Villar to testify that he conducted the
ballistics examination and to attest to the veracity of his findings in the said
report.
7. Chemist Dionisia Paqui to testify that she conducted a paraffin test to
the accused and to attest to the veracity of her findings in the said report.

TRIAL DATES
Specifically all Fridays of the month, with the regular appearance of the
undersigned city prosecutors before this Honorable Court.
RESPECTFULLY SUBMITTED.
Cebu City, Cebu, Philippines, July 4, 2016.

CEBU CITY PROSECUTORS OFFICE

Ramon Q. Avancea Hall of Justice
Sotto Drive,Cebu City

By:
JERICHO C. ROSALES
Assistant City Prosecutor
Roll No. 67890 / 5-2-07
IBP. No. 667899 / 12-29-07
MCLE Exempt
PTR Exempt

And

JENNYLYN B. MERCADO
Assistant City Prosecutor
Roll No. 67891 / 5-2-07
IBP No. 667900 / 12-29-07
MCLE Exempt
PTR Exempt

Copy furnished:
ATTY. KRIS C. AQUINAS
Counsel for the Defense
Room 200, New Valentine Bldg.
Central Philippine University
Lopez Jaena St., Jaro, Iloilo City

Received by:___________
Date: ___________