pre trial brief
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Pre Trial BriefTRANSCRIPT
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REPUBLIC OF THE PHILIPPINES
REGIONAL TRIAL COURT
LUCENA CITY
BRANCH___________
PEOPLE OF THE PHILIPPINES CRIMINAL CASE NO.____
Plaintiff (NPS Docket No._______)
-versus- -for-
ROBBERY
ATTY. SIR CHIEF, JINGGOY,
JUAN AND JOAQUIN
Accused
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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 FACTSAND 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, Maya’s 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 PROSECUTORS’S 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 RAMIREZATTY.EDELYN AYANGCOATTY.JOHN MARK SAPORNACounsels for the Defense
Received by:____________
Date: _________________
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