ECUMENICAL PRAYER

Almighty God, we stand in Your Holy presence as our Supreme

Judge.

We humbly beseech you to bless and inspire us so that what we

think, say and do will be in accordance with Your will.

Enlighten our minds, strengthen our spirit and fill our hearts with
fraternal love, wisdom and understanding, so that what we can become
effective channels of truth, justice and peace.

In our proceeding today, guide us in the path of righteousness for the

fulfillment of Your greater glory. Amen.

Criminal Case No. 4647

People of the Philippines versus Ryan Martinez for Reckless Imprudence

Resulting to Double Homicide and Damage to Property (Art.365)

PROSECUTION:
Fiscal: For the prosecution, Your Honor (YH), representing the
People of the Phils.
I am ___________________________

ABG: Good morning YH, I am _____________________________

respectfully appearing as private prosecutor for private
complainant Lorena Lorenzo, under the direct control
and supervision of the Honorable Prosecutor Virgie Ines
Lomuntad Your Honor, together with my co private
prosecutor….

Good morning YH, I am ____________________

Defense:

: We are ready, YH.

 2

PRE-TRIAL

THEORY OF THE PROSECUTION:

That the accused is guilty of the crime of Reckless Imprudence Resulting to

Double Homicide and Damage to Property

THEORY OF THE DEFENSE:

Plea Bargaining

J: Are the parties willing to agree to enter into a plea-bargaining?

PROS:
Your Honor Please (YHP), the prosecution does not desire to enter
into plea-bargaining.

DEFENSE: YHP, the defense is not willing to enter to plea bargaining.

Admissions

J: Any admission?

(By the Prosecution)

PROS: YHP, the prosecution requests for the admission by the defense of
the following facts:

Does the defense admit that:

1. That the Hon. Court has jurisdiction over this case;

2. That the accused Ryan Tacata Martinez is the same person who is
charged and arraigned in the information;

3. That the accused knows personally Tristan Joy Lorenzo and Christian
Philip Agravante;

4. That on June 27, 2018, the accused Ryan Tacata Martinez was with
Tristan Joy Lorenzo and Christian Philip Agravante;

5. That on the early morning of June 27, 2018, the accused together with
Tristan Joy Lorenzo and Christian Philip Agravante and their
companions namely Aristotle Riveral, Jhumer Cristobal, Whilly Porillo,
Aervelle Clyde Pascua, Aerolle Khave Pascua were going to Laoag City
from Pagudpud, Ilocos Norte;

6. That all of them were riding a Toyota Hi-Ace colored silver metallic van
with Plate No. PSQ 814, registered under the name of Amor Dancel
Galat.

7. That the one who drove and was then driving the Toyota Hi-ace van
was the accused Ryan Tacata Martinez;
 3

8. That while they were in the vicinity of Brgy. 30, Cadaratan, Bacarra,
Ilocos Norte, the Toyota van figured in an accident as it bumped the
western portion of the Bacarra welcome arch at the western shoulder of
the highway;

9. That as a result, Tristan Lorenzo died due to multiple injuries

secondary to vehicular accident, likewise as a result of said accident,
Christian Philip Agravante also died for the same reason.

10. That as per police investigation, the driver of the Toyota Hi-Ace van
when it figured in said accident was the accused Ryan Tacata Martinez;

11. That as per investigation of the police officers, the accused Ryan
Tacata Martinez was then under the influence of liquor.

12. That the accused Ryan Tacata Martinez is also charged with violation
of RA 10586 or the Anti Drunk and Drugged Driving Law in relation to
this case, now pending before the Regional Trial Court Branch 12,
Laoag City, docketed as _________________.

13. That the accused was taken from the driver’s seat by the responders.

14. That the accused had no driver’s license at the time of the accident.

15. That accused Ryan Tacata Martinez was issued a Traffic Citation
Ticket for reckless driving, driving without license and driving under
the influence of liquor

16.

Admission of Documentary Evidence

: With the permission of the Honorable Court.

ABG YHP, the prosecution requests for the admission by the defense
of the authenticity and due execution of the following
documents:

A. Affidavit of Investigator

B. Investigation Report

C. Certificate of Police Blotter Extract

D. Sketch of the place of incident

E. Request for Medical Report

F. Medico-legal Certificate of Ryan Tacata Martinez

G. Certification from Bacarra Medical Center showing that Tristan Joy

Lorenzo was Dead on Arrival when brought thereat

 4

H. Certificate of Death of Tristan Joy Lorenzo

I. Certificate of Death Christian Philip Agravante

J. Parts of investigation – photos or pictures depicting the place of

incident as well as that of the van which was taken by the investigators

K. Traffic Citation Ticket No. 1069

L. The receipts for funeral expenses

1. OR No. 0084 Ripa Funeral Home and Services – PHP 150,000.00

2. Catering Contract (Nening’s Banquet Catering Services (PHP

130,000.00)

3. Robinsons Supermarket Sales Invoice No. 0000114648 (Php 15,

918.55)

4. Robinsons Supermarket Sales Invoice No. 0000131495 (Php

4,317.30)

5. E-Grocery receipt (Php 2, 720.00) - OR No. 0000051922

6. Aicel Express General Merchandise (Php 320.00) – OR No. 4092

PROS: The prosecution admits/does not admit, YH.

ABG: No further request for admissions, YH.

Identification of Issues

J: So what are the issues to be resolved?

PROS.
YHP, the prosecution submits the following issued to be
resolved:
1. WON the accused is guilty of Reckless Imprudence
Resulting to Double Homicide and Damage to Property

2.

J: How about the defense?

DEFENSE

1.
 5

Marking of exhibits

Prosec: The prosecution will present the following documentary evidence

and request that these be marked as follows:

Exhibit:
A. Affidavit of Investigator

B. Investigation Report

C. Certificate of Police Blotter Extract

D. Sketch of the place of incident

E. Request for Medical Report

F. Medico-legal Certificate of Ryan Tacata Martinez

G. Certification from Bacarra Medical Center showing that Tristan Joy

Lorenzo was Dead on Arrival when brought thereat

H. Certificate of Death of Tristan Joy Lorenzo

I. Certificate of Death Christian Philip Agravante

J. Parts of investigation – photos or pictures depicting the place of

incident as well as that of the van which was taken by the investigators

K. Traffic Citation Ticket No. 1069

L. The receipts for funeral expenses

A. OR No. 0084 Ripa Funeral Home and Services – PHP 150,000.00

B. Catering Contract (Nening’s Banquet Catering Services (PHP

130,000.00)

C. Robinsons Supermarket Sales Invoice No. 0000114648 (Php 15,

918.55)

D. Robinsons Supermarket Sales Invoice No. 0000131495 (Php

4,317.30)

E. E-Grocery receipt (Php 2, 720.00) – OR No. 0000051922

F. Aicel Express General Merchandise (Php 320.00) – OR No. 4092

M.
 6

The prosecution, YH, reserves its right to introduce submarkings to the

pre-marked exhibits and present other documentary evidence during
the course of the trial.

Number of Witnesses

PROS.
The prosecution will present ___ witnesses, YH. ….

1. PO1 Jonathan C. Lazaro, investigator on case

2. Beat Patroller PO3 Gian Karlo Diego
3. PO1 Jaylord M. Juan
4. Hostile witness – Aerolle Khave T. Pascua
5. Hostile witness – Aristotle D. Riveral
6. FO2 Norman Cascayan
7. Dr. Allan Peter Dela Cruz (GRBASMH)
8. Dr. Juanita Marita A. Cua (Bacarra Medical Center
9.

The prosecution reserves its right to present other witnesses in the course
of the trial, YH.

J: Alright, how about the defense, how many witnesses?

DEFENSE:

YHP, the defense will present ___ witnesses.

1.
2.
3.

J: Alright, are the parties willing to consider the pre-trial

terminated?

PROS/DEF. Yes, YH.

J: Subject to the issuance of the Pre-trial Order, the pre-trial of

this case is hereby terminated.