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Republic of the Philippines

Sixth Judicial Region


REGIONAL TRIAL COURT
Branch___
Iloilo City

PEOPLE OF THE PHILIPPINES, CRIMINAL CASE NO._______


Plaintiff, FOR:
ROBBERY WITH HOMICIDE

- versus -

TITO CRUZ AND VIC CRUZ,


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 Joey Cruz, 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 Geraldine Demetri
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 Bea Robles
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 Michaels
Purpose: to corroborate the testimonies of Geraldine Demetri and Bea Robles;
3. Autopsy Report of Joey Cruz issued by Iloilo Mission Hospital
Purpose: to prove the extent of the injury and the cause of death of the victim;
4. Blotter Report of Jaro Police Station (ICP-PP3)
Purpose: to prove that the police authority received a report that a robbery took
place at Iloilo Supermart, located at Tabuk Suba, Jaro, Iloilo 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 victim’s body was shot and the nature,
extent and location of wound.
8. Ballistics Test result
Purpose: To prove that the slug recovered from the victim’s body came from the
same gun which was recovered from the possession of Tito Cruz.
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. Geraldine Demetri to testify that a robbery took place;
2. Bea Robles to testify that she was one of the customers of the Iloilo
Supermart at the time the robbery took place;
3. Paris Michaels 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 Joey Cruz 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.
Iloilo City, Iloilo, Philippines, July 4, 2008.
ILOILO CITY PROSECUTOR’S OFFICE
Ramon Q. Avanceña Hall of Justice
Bonifacio Drive,Iloilo City

By:

JOHN FRED C. HALLARES


Assistant City Prosecutor
Roll No. 67890 / 5-2-07
IBP. No. 667899 / 12-29-07
MCLE Exempt
PTR Exempt

And

JASIE ANN MAGHOPOY


Assistant City Prosecutor
Roll No. 67891 / 5-2-07
IBP No. 667900 / 12-29-07
MCLE Exempt
PTR Exempt
Copy furnished:

ATTY. KENETH P. TUPAS


Counsel for the Defense
Room 200, New Valentine Bldg.
Central Philippine University
Lopez Jaena St., Jaro, Iloilo City

Received by:___________
Date: ___________