September 16, 2019

Judge: Call the case.

Clerk: Criminal Case No. 001. People of the Philippines vs. PO1 Nick Polutan and PO2
Pat Tinio for Murder punishable under Art. 248 of the Revised Penal Code.

Judge: Appearances?

Defense: Atty. Orteza and Atty. Gerald Anderson presenting for the accused, Your
Honor.

Prosecutor: Prosecutor Yu and Prosecutor Cosare appearing for the People, Your
Honor.

Judge Vasquez: Ready?

Prosecutor & Defense: Yes, Your Honor.

Judge Vasquez: Today’s hearing is for the presentation of additional witness for the
defense. Who is your additional witness, Atty. Orteza?

Defense: First, I would like to call our forensic expert, Ms. Loisy Juguan, your Honor.

[ swearing of the witness ]

Clerk of Court : Kindly state your name, age, address, and other personal
circumstances.
A: I’m Loise Juguan, Forensic Expert, 32 years old, I live in Makati City.

Clerk of Court: The witness is ready, Your Honor.

DIRECT EXAMINATION

Defense: Your Honor, we would like to present the testimony of the witness to prove that
the gun obtained from the crime scene bore the fingerprints of the victim, Joshua de
Gracia.

Judge Vasquez: Any comment or opposition on the purpose for which the testimony of
the witness is being offered?

Prosecutor: None, Your Honor. Subject to cross.

Judge Vasquez: Proceed.

Q: Good morning, Ms. Witness. For clarification purposes, kindly state your name and
your occupation.
A: I’m Loise Juguan, I am a Forensic Expert in the Makati Laboratory.

Q: How long have you been in your profession?

A: I have been in my profession for almost 6 years.

Q: Can you describe the functions of your office?

A: We do collect and analyze data from the crime scene.

Q: Do you have any certification whatsoever to prove that you are in fact accredited to
conduct such functions?
A: Yes, sir

Q: Where is your principal office?

A: In the Makati Laboratory.

Q: Okay, I’ll show you a document, can you please tell the court what this document is?
A: That is my identification card in Makati Forensic Laboratory.

Defense: Let the record show that the witness identified the document known as Exhibit
6 as her identification card in the Makati Forensic Laboratory.

Q: Okay, I’ll show you another document, can you please tell the court what this
document is?
A: That is my Certification of Employment coming from my office, and also coming from
the Police Station.

Defense: Let the record show that the witness identified the document known as Exhibit
7 as her Certification of Employment from the Makati Police Station that certifies her as
a Forensic Analyst in the Makati Laboratory.

Q: Ms. Witness, have you ever been presented in any court as an expert witness prior
to this day?
A: Yes, sir.

Q: Can you please tell us which case, if any, were you presented as an expert witness?
A: I have been an expert witness in RTC of Makati and MTC of Makati.

Q: I’m gonna show you a document, can you please tell the court what this document
is?
A: That is a certification that came from the MTC that I appeared in court for the case of
People v. Santos.

Defense: Let the record show that the witness identified the document to be marked as
Exhibit 8, a Certificate from MTC which certifies that she appeared in court as an expert
witness for the case of People v. Santos.

Q: Ms. Witness, I’m gonna show you another document, can you please tell the court
what this document is?
A: That is a certification that I appeared in the RTC Makati for the case of People v. Tan.

Defense: Let the record show that the witness identified the document to be marked as
Exhibit 9, as her Certification that she appeared as an expert witness in RTC Makati for
the case of People v. Tan.

Q: Ms. Witness, please tell the court where you received your degree in forensic
medicine.
A: I took my Forensic Medicine in University of Baguio.

Q: I’m gonna show you a document, can you please tell the court what this document
is?
A: That is my diploma.

Defense: Let the record show that the witness identified the document marked as
Exhibit 5, her diploma from University of Baguio for a degree in BS Forensic Science.

Q: Is the prosecution satisfied with the qualifications of our expert witness?

Prosecutor: From which certifying institution and from what year did you earn your
certificate as a forensic expert?

Defense: Objection, your Honor. That was already established a while ago.

Judge Vasquez: Sustain.

Prosecution: No further questions. Subject to cross, your Honor.

Judge Vasquez: In that case, considering that the Prosecution is already satisfied that
the witness is an expert witness, then we can now proceed with your questions.

Defense: Thank you, your Honor. May I proceed?

Judge Vasquez: Kindly proceed, Atty. Orteza.

Q: Ms. Witness, please tell this court where you were on the night of July 8, 2018.
A: I was working at the lab, then the Makati Police Station called me to go to Poblacion,
Makati.

Q; Why did the Police Station called you to go to Poblacion?

A: There was an incident, and we were tasked to collect any evidence that can be found
in the crime scene.

Q: When you arrived in the crime scene, what sort of evidence did you find? Or what did
the police hand to you?
A: The police hand to me a gun for purpose of identifying if there are fingerprints on it.
Q: Can you describe this gun, Ms. Witness?
A: It’s a .45 caliber Colt Hartford gun.

Q: I’m going to show you a gun, and please tell the court if this is the same gun that was
handed to you at the night of the crime that was found in the crime scene.
A: Yes, this was the gun.

Defense: Let the record show that the witness identified the document previously
marked as Exhibit 4, as the same gun that was obtained from the crime scene.

Q: Ms. Witness, why was it handed to you again?

A: We ran diagnostics, and we were trying to find out who had the gun during the
incident.

Q: And what was the result of such test?

A: There were 2 fingerprints found in the gun.

Q: Whose fingerprints were those?

A: The first fingerprint found belong to SPO2 Pat Tinio, and the other one is the
deceased’s, Joshua de Gracia.

Q: Do you have any document proving such results?

A: Yes, I sent the report to the Makati Police Station.

Q: Q: I’ll show you a document, please tell the court what this document is.
A: It was the examination of the fingerprints found in the gun.

Q: Can you please tell us whose signature is this appearing at the bottom of the
document?
A: It is my signature.

Defense: Let the record show that the witness identified the document bearing the
fingerprints of PO2 Pat Tinio and the victim, Joshua de Gracia, previously marked as
Exhibit 3.

Q: Ms. Witness, are you authorized to issue such document?

A: Yes, sir.

Defense: No further questions, your Honor.

Judge Vasquez: Okay. Cross.

CROSS EXAMINATION

Prosecutor: May I proceed, your Honor?

Judge Vasquez: Kindly proceed, Fiscal Yu.

Q: Ms. Witness, when you were asked earlier where were you last July 8, 2018, you
said you were in the lab and you were called to attend in the crime scene. If I may ask,
how long did it take you to arrive at the crime scene?
A: It took me 20 mins. to arrive in the crime scene.

Q: You also stated earlier that you examined the gun found in the crime scene, how
many gun did you examine?
A: There was only 1 gun that was handed to me by the Makati Police Station.

Q: Did you examine any bullet slugs that night?

A: It was examine by the other forensic analyst.

Q: You stated earlier that in your report, it is positive that the fingerprint found on the
gun was Joshua’s, and the result is 98%, is it possible that you will arrive with the same
result if the victim is already dead and the gun was placed in his hand?
A: Possible.

Prosecutor: I would like to put it on record, your Honor, that the witness paused before
answering the question.

Judge Vasquez: Alright, noted.

Prosecutor: No further questions, your Honor.

Judge Vasquez: Any redirect question?

Defense: No redirect questions, your Honor.

Judge Vasquez: So if there is no redirect question, the witness is excused. Next

witness?

————————

[ swearing of the witness ]

Clerk of Court : Kindly state your name, age, address, and other personal
circumstances.

A: I am Felix Ambrosio, 35 years old, a resident of Jupiter, Poblacion, and I am a

construction worker.

Clerk of Court: The witness is ready, your Honor.

Defense: Your Honor, we would like to present our next witness, Felix Ambrosio, as an
eyewitness to prove that the victim, Joshua de Gracia, showed unlawful aggression
during the altercation, and that the police officers did exercise their reasonable means
to justify their self-defense and that there was no sufficient provocation on the part of
the accused.

Judge Vasquez: Okay, any comment or opposition?

Prosecutor: None, your Honor. Subject to cross.

Q: Mr. Witness, for clarification purposes, kindly state your name and your occupation, if
any.
A: I am Felix Ambrosio, a construction worker.

Q: Where are you from, Mr. Witness?

A: I am from Poblacion, Makati.

Q: How long have you been living there?

A: About 20 years.

Q: Do you know a certain Joshua de Gracia from your neighborhood.

A: Yes, sir.

Q: Mr. Witness, please describe physical attributes of the Joshua de Gracia that you
know?
A: He has a nice body, he is tall and he is an expert in gym since he lifts heavy weights.

Q: Where were you on the night of July 8, 2018?

A: Around 7:30 in the evening, I was buying cigarette at a nearby store along Jupiter
street where the incident happened.

Q: Did anything unusual happened during that evening?

A: Yes since what happened was I was buying cigarette then someone who is handcuffs
is shouting with a statement “papatayin ko kayo, papatayin ko kayo”.

Q: Mr. Witness, can you tell this court who was this person in handcuffs and shouting?
A: It was Joshua de Gracia, a friend of mine.

Q: And then what happened when you heard this commotion, Mr. Witness?
A: I hid behind a post beside the store because I was so scared. But even though I’m
hiding, I could still see what was happening since I was peeping in between the 2 posts.
Then I saw Joshua kicked the policewoman.

Q: Can you please identify if that policewoman that was kicked by the victim is in this
courtroom?
A: Yes, sir. [The accused points to the lady sitting with a long hair, wearing a yellow
blouse]

Clerk of Court: The witness was pointing to a woman with a long hair, wearing a yellow
blouse, and who when asked of her name answered “PO2 Pat Tinio”.

Defense: Let the record show that the witness identified PO2 Pat Tinio as the
policewoman who was kicked by the victim, Joshua de Gracias.

Q: Mr. Witness, can you please describe the physical attributes of the police officer in
question that was kicked by Joshua?
A: She has a long hair, a small face, a petite figure, and she’s not that tall. During that
time it was not that dark, I was not able to identify her fully. But now I can fully confirm
that it was her.

Q: What happened next after Joshua kicked the police officer?

A: She fell on the ground, then while being on the ground, she was gradually reaching
for the gun but failed to do so. Instead, she was able to reach for a stone and used it to
hit Joshua on the face. After that, the gun was accidentally used by the policewoman to
shot Joshua’s leg.

Q: Mr. Witness, was there any other police officer present during the scene?
A: Yes, sir. As I was buying cigarette, then I immediately hid behind a post when the
incident occurred, she was accompanied by another police officer buying “Coke”.

Prosecutor: Objection, your Honor. The witness is narrating.

Judge Vasquez: Okay, answer in short sentences only so that the interpreter can easily
translate your answer.

Q: And then what happened next, Mr. Witness?

A: After the policewoman accidentally shot Joshua, there was another police officer - the
one buying at the store - a policeman, who saw the incident and went immediately there
since they - the policewoman and Joshua - were struggling to get the gun. And then that
police officer made a warning shot - gunshot towards the air - and said “oy tigil, ibaba
mo yan”.

Q: The gun that was being referred to, can you tell us in whose possession was the gun
during that time?
A: During the incident, the gun was already in possession of Joshua.

Q: How many gunshots did you hear?

A: I heard around 5 gun shots.

Q: Right after the policeman fired a warning shot, what happened next?
A: There was a quick turn of events, but as far as I could remember, Joshua was still
shouting “papatayin kita, papatayin kita” then the gun was pointed towards the
policewoman.

Q: Mr. Witness, when the police officer fired the warning shot, did Joshua put down the
gun in question?
A: Joshua did not put down the gun despite the police officer’s order, instead he was still
pointing it towards the policewoman.

Q: What happened after?

A: Since Joshua did not put down the gun, the policeman again fired the gun - hitting
Joshua’s shoulder.

Q: And then what happened?

A: Since Joshua did not put the gun down and was still pointing towards the
policewoman even though Joshua was in handcuffs, the policeman fired the gun
directly towards the back of Joshua’s head. Because of simultaneous gun shots,
with regard to the fourth and fifth gun shots, those were the shots fired to the
lower head part of Joshua. I’m not sure if he died but they called a medic. (45:46,
recording no. 5)

Defense: Thank you, Mr. Witness. No further questions, your Honor.

Judge Vasquez: Cross.

CROSS EXAMINATION

Prosecutor: May I proceed, your Honor?

Judge Vasquez: Kindly proceed, Fiscal Yu.

Q: Mr. Witness, you stated earlier that you were at the crime scene last July 8, 2018,
correct?
A: Yes, sir.

Q: When you were asked what you were doing there, you answered that you were
buying cigarettes?
A: Yes, sir.

Q: Despite the presence of the police officers, you were buying cigarettes even though
cigarette smoking is prohibited in Makati?

Defense: Objection, your Honor. The question is irrelevant.

Prosecutor: Your Honor, I am just trying to establish the character of the witness, that
the witness is violating a City Ordinance.

Judge Vasquez: But, is buying a violation?

Prosecutor: No, your Honor.

Judge Vasquez: Objection sustained. Kindly reform your question.

Q: When you were asked earlier where were you during the incident, you said that you
hid behind a post, were you afraid during those time that’s why you hid?
A: Yes, sir.

Q: How far were you from the incident?

A: About 6 to 7 meters.

Q: When you were asked earlier, you said “masyadong mabilis ang pangyayari” (there
was a quick turn of events), is it possible to state that you are not so sure with your
narration of the events?
A: No, sir. Given that the incident happened with sufficient lighting, I was able to identify
the incident - was happening. (The witness asked if he could add more, but the Fiscal
refused)

Q: When you were asked earlier, you answered that one of the police officers shot the
victim in the head, is that correct?

Defense: Objection, your Honor. Interpretation was inaccurate. The witness stated
earlier that the police officer and the victim exchanged gunshots.

Prosecutor: It was stated in the record that the police officer shot the victim in the head.

Judge Vasquez: Kindly have the translation corrected. Based on the record, the phrase
stated was “fired directly towards”.

Prosecutor: May I proceed, your Honor?

Judge Vasquez: Kindly continue, Fiscal Yu.

Q: You answered earlier that after the incident, they called for a medic, after that what
did you do?
A: I left, sir.

Q: You left without reporting to the police that you witnessed the incident?
A: None, sir. I volunteered to be one of the witnesses due to my conscience which
causes my sleepless nights since I just ran away despite the fact that I know the person
involved in the incident, thus I reported it to the police. That is why I was belatedly
presented as witness. Also, I want to help in resolving the case.

Q: You were asked earlier to describe the physical appearance of the police officers
involved, do you know them personally?
A: No, sir.

Q: Were you threatened by these police officers?

A: No, sir.

Q: Are you sure?

A: Yes, sir.

Prosecutor: No further questions, your Honor.

Judge Vasquez: Okay, redirect.

REDIRECT EXAMINATION

Defense: May I proceed, your Honor?

Judge Vasquez: Kindly proceed, Atty. Orteza.

Q: Mr. Witness, you said earlier that you were around 6 meters away from the crime
scene, can you describe the lighting in the scene?
A: Given the fact that the area is considered is part of the Red Light District, it has
sufficient lighting.

Q: Can you describe your eyesight?

Prosecution: Objection, your Honor. Irrelevant. It was not asked earlier.

Defense: Your Honor, the question is relation with the earlier question with regard the
lighting. I am trying to establish whether the witness clearly saw the occurrence of the
incident.

Judge: Overrule. Witness may answer.

A: 20/20, sir, since it is required in my work.

Q: Can you expound on your previous answer with regard the fourth and fifth gunshots
that you heard?
A: With respect to the fourth and fifth gunshots, those were made simultaneously as
exchange of gunshots. The gunshot fired by Joshua missed the policeman named Nick
Polutan. But the gunshot fired by the policeman hit Joshua,

Prosecutor: I would like to put on record that the witness paused in rethinking his
previous answer.

Judge Vasquez: Noted. Please proceed.

Q: Mr. Witness, as stated earlier, there were exchange of gunshots, specifically the
fourth and fifth. So, who fired the fourth gunshot?
A: It came from Joshua, sir.

Q: For clarification purposes, because of your 20/20 eye vision, did you happen to see if
the police officer who fired the fifth gun shot aimed for Joshua’s head?
Prosecutor: Objection, your Honor. Opinion.

Defense: Your Honor, the witness has a first-hand account of what happened. Thus, he
must have known whether the police officer was aiming for Joshua’s head.

Judge Vasquez: Sustain. It is from the point-of-view of the person who fired the shot,
which is different from the point-of-view of the witness. Thus, the witness is not in the
position to know whether the police officer was really aiming at the back of the head.
Kindly reform your question, attorney.

Q: During the exchange of gunshots, as to the fifth gunshot, would you happen to see
how the accused aimed is gun? High or low?
A: Based on what I saw, the accused aimed the gun downward.

Q: How can you explain it hitting the back of Joshua’s head if the gun was aimed low?

Prosecutor: Objection, your Honor. Witness not qualified to answer.

Judge Vasquez: Sustained.

Q: Can you describe the position of the victim, Joshua, during the exchange of
gunshots?
A: He was on a defense position during the exchange of gunshots. He was not in a
stable position since he was trying to evade the shot.

Q: What took you so long to come forward and why were you not available during the
earlier stages of the proceeding?
A: I immediately left after the incident because of fear and I also do not want to get
involved in what was happening. But because of my conscience and sleepless nights, I
voluntarily went to the police station to help resolve the case.

Defense: No further questions, your Honor.

Judge Vasquez: Re-cross.

RE-CROSS EXAMINATION

Prosecutor: May I proceed, your Honor?

Judge Vasquez: Kindly proceed, Fiscal Cosare.

Q: Mr. Witness, what were you feeling during the time that you were witnessing the
incident?
A: At first I took pity of my friend - handcuffed with police officers, however, during the
exchange of gunfires, I already got scared so I left.

Q: You mentioned earlier that according to your word, “mabilis ang pangyayari” (there
was a quick turn of events), is that correct?
A: Yes, sir.

Q: Prior to July 8, 2018, when was your last eye check-up?

A: Last July 1, 2018, since I am just new in my work and it was one of the requirements.

Prosecutor: No further questions, your Honor.

Judge Vasquez: Thank you. Witness is excused.

[ RECESS ]

Judge Vasquez: Appearances?

Defense: Atty. Orteza and Atty. Gerald Anderson presenting for the accused, Your
Honor.

Prosecutor: Prosecutor Yu and Prosecutor Cosare appearing for the People, Your
Honor.

Judge Vasquez: Ready? Do you still have other witnesses?

Defense: None, your Honor.

Judge Vasquez: Ready to formally offer your documentary exhibits?

Defense: We would like to offer the following:

First, Exhibit 1-A, the mission order issued by Supt. Baron Bado to prove that there
was a valid police operation conducted last July 8, 2018 involving the accused.
Second, we would like to formally offer the drug watch list to prove that the name of
Joshua de Gracia appeared on such list from Brgy. Poblacio, Makati City.
Third, the results of the examination conducted and certified by Ms. Juguan, the
forensic expert, whereby such examination yielded that the gun obtained from the crime
scene contains the fingerprints of the victim, Joshua de Gracia.
Fourth, the gun previously marked as Exhibit 4, belonging to PO2 Pat Tinio, that was
taken by Joshua, thus baring his fingerprints.
Fifth, the document previously marked as Exhibit 5, the diploma of Ms. Juguan, our
forensic expert, obtained from the University of Baguio.
Sixth, the document previously marked as Exhibit 6, the photocopy of the
identification card of Ms. Juguan as an employee as forensic analyst of Makati
Forensic Laboratory.
Seventh, the document previously marked as Exhibit 7, the certificate of Ms. Juguan,
officially certifying the same as forensic analyst with a right to perform his functions for
all evidence obtained.
Eighth, the document previously marked as Exhibit 8, the certificate of Ms. Juguan to
prove that she had previously been a forensic expert in MTC Makati in the case of
People v. Santos.
Ninth, the document previously marked as Exhibit 9, the certificate of Juguan as
forensic expert witness in RTC Makati in the case of People v. Tan.
That is all, your Honor.

Judge Vasquez: Comment or opposition?

Prosecutor: None, your Honor.

Judge Vasquez: Considering that there is no objection or comment to the formal offer
made by the Defense, this Court hereby resolves to admit Exhibits 1 to 9 together with
the sub-markings offered.

Defense: The Defense would like to rest our case.

Judge Vasquez: Any rebuttal evidence from the Prosecution?

Prosecutor: Yes, your Honor.

Judge Vasquez: Are you ready to present your witness today, Prosecutor?

Prosecutor: Yes, Your Honor.

Judge Vasquez: Ready?

Prosecutor: Our first witness is Mrs. Ligaya de Gracia, the mother of the victim.

[ swearing of the witness ]

Clerk of Court : Kindly state your name, age, address, and other personal
circumstances.

A: Ligaya de Gracia, 36 years old, a resident of Brgy. Poblacion, Makati.

Clerk of Court: The witness is ready, your Honor.

Judge Vasquez: Fiscal Cosare, kindly proceed.

Prosecutor: We are presenting Mrs. Ligaya de Gracia for purposes of establishing the
personality of the victim, Joshua de Gracia. May I proceed your Honor?

Judge Vasquez: Any comment or opposition to the purpose for which the witness is
being offered?

Defense: None your Honor. Subject to Cross.

Judge Vasquez: Kindly proceed, Fiscal Cosare.

Q: Just to establish and clarify, you are the mother of the victim, Joshua de Gracia, is
that correct?
A: Yes, sir.

Q: Are you sure you can answer my questions?

A: I am disgruntled, but I will do my best.

Q: When the incident happened on July 8, 2018, where were you exactly at that time?
A: I was with my son at my sibling’s house.

Q: How is Joshua as a son? How was his health condition at that time?
A: My son had an illness called ADHD, he is a special child.

Q: When and how did you know that Joshua actually have ADHD?
A: I was only 7 months pregnant when I gave birth to Joshua, and I was only 19 years
old that time.

Q: Who diagnosed or told you that Joshua has ADHD?

A: I brought him in a health centre and they said that Joshua has ADHD.

Q: What are the other manifestations of this ADHD, like in emotional aspect?

Defense: Objection, your Honor, the witness is not qualified to answer as to the
manifestations since she is not an expert/doctor.

Prosecutor: The witness is not the doctor, but more than anything else, your Honor, she
is the mother, thus she knows the manifestations.

Judge Vasquez: From a layman’s point of view, witness may answer.

A: First, he has slow development with respect to his mental capabilities and was only
able to learn to speak when he was 1 year old. To which we considered him as deaf-
mute.

Q: Ms. Witness, I would like to clarify, when you say that he only started to speak on his
first year, what do you exactly mean?

Defense: Objection, your Honor. Leading question.

Prosecutor: No, your Honor. What we are trying to do here is we are trying to clarify
because the witness has contrary answers. She said that initially Joshua was unable to
speak, then in his first year he was already able to speak. So, what I’d like to clarify is
what was he producing - and exact word or some sounds.

Judge Vasquez: Okay, witness may answer but kindly reform your question.

Q: Ms. Witness, when you said that when he was 1 year old, he was able to speak.
What do you exactly mean?
A: When my child was in his first year, that is the only time that he was able to produce
some sounds.

Q: Going further, Ma’am, what was Joshua’s highest educational attainment?

Defense: Objection, your Honor. The question is irrelevant.

Prosecution: The ultimate purpose of presenting the mother is to establish the victim’s
character. In this case, your Honor, education is part of the victim’s character.

Judge Vasquez: Okay, witness may answer.

A: My son only finished sixth grade.

Q: What was the reason why he only finished sixth grade?

A: Like what I have said earlier, the reason why he only finished sixth grade was
because of his slow mental development. And he is also suffering from anger
management.

Q: Where were you when the incident happened?

A: I was with my son at my brother’s house, Ben de Gracia.

Q: Why were you there?

A: Being only a wet-market vendor, I was borrowing money from my brother. I cannot
fully provide Joshua’s needs that is why I was borrowing money from Ben.

Q: Where were you exactly and what were you doing when the police came?
A: We were seated at the sala of my brother’s house. And we were shocked when the
police officers opened the door. I was shocked when my brother, Ben, passed through
the window and flee.

Q: When your brother ran away, what happened next?

A: The other police officers ran after my brother, and the other police officers - the
accused - were the ones who arrested my son.

Q: Were you presented with any document stating that they are authorized to arrest
your son?
A: They said that they were arresting my brother, but they only showed me a piece of
paper without showing its contents.

Q: Can you identify either of the police officers that you were mentioning, if that person
is present in this room?
A: Yes. The lady wearing a yellow blouse. You are the one who killed my son. [The
accused points to the lady sitting with a long hair, wearing a yellow blouse]

Clerk of Court: The witness was pointing to a woman with a long hair, wearing a yellow
blouse, and who when asked of her name answered “PO2 Pat Tinio”.

Q: Can you still answer, Ms. Witness?

A: Yes, for my son’s justice.

Q: You mentioned that one of the police officers is here and that she arrested your son.
After that arrest, what happened?
A: They took my son and they told me to find my brother, Ben. And told me to bring my
brother in exchange of my son.

Q: Ms. Witness, can you still answer my questions?

A: Yes, sir.

Q: You mentioned that they told you to look for your brother in exchange of your son.
Given that advice, what did you do?
A: I tried to look for my brother. I even called our other relatives to help me.

Prosecutor: Your Honor, it seems like the witness is getting too emotional. May we move
for continuance, your Honor, because the witness seems to be emotionally unstable?

Defense: We would like to put on record that the Prosecutor said that the witness was
emotionally unstable.

Prosecutor: Your Honor, when I said emotionally unstable, what I meant was the witness
is crying and it seems like if we continue, she might suffer breakdown or heart attack.

Defense: We would also like to put on record that the witness is crying and at the same
time laughing, so her sanity might be questionable. (on record but disregard; just for fun
)

Judge Vasquez: So, would you like to move for continuance?

Prosecutor: Yes, your Honor.

Judge Vasquez: Okay, I will grant the motion for continuance. But next time I will no
longer grant any delay in the presentation of the witness.

Prosecutor: Thank you, your Honor.