REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
BRANCH 1, MANILA
PEOPLE OF THE PHILIPPINES
Plaintiff,
-versus-

Criminal Case No.

1234
For: Robbery
JUAN DELA CRUZ
Accused,
x----------------------------------x
INFORMATION
The undersigned, provincial fiscal, upon sworn complaint
originally filed by the offended party, accuses JUAN DELA CRUZ of the
crime of Robbery, committed as follows:
That on or about September 14, 2016 around 02:00am, in the
City of Manila, Philippines, within the jurisdiction of this Court, the said
accused, actuated by just, did then and there, willfully, unlawfully, and
feloniously, take the personal properties of the victim with intent to
gain amounting to P100,000 there being effected by the means of
using false keys, picklocks or similar tools to the house of the victim.
Manila, Philippines, this 14th day of September, 2016
Ninz Berdonar
Public Prosecutor
WITNESSES

CERTIFICTION
This is to certify that a preliminary investigation has been conducted in
accordance with the law; that the complaint and her witnesses have

been examined and that on the basis of the sworn statements and
other evidence submitted, there is reasonable ground to believe that
the crime has been committed and the accused are probably guilty
thereof, that the accused were informed of the complaint and the
evidence submitted against them, and that they were given an
opportunity to submit contrary evidence.
Cassie Lopez
Assistant Prosecutor
Subscribed and sworn to before me, this 14th day of September, 2016
in the City of Manila affiant exhibiting before me his Community Tax
Certificate No. 1234, issued at Manila on September 15, 2016.
Atty. Juan Dela Cruz
S. N. 09-22222
Notary Public
Roll No. 0909
P. T. R. No. 76895 12/31/2007, Manila
IBP No. 0009 12/31/2007, Manila.
Doc. No. 5;
Page No. 6;
Book No. IV;
Series of 2016

REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION
REGIONAL TRIAL COURT
BRANCH 1, MANILA
PEOPLE OF THE PHILIPPINES
Plaintiff,
-versus-

Criminal Case No.

1234
For: Robbery
NATHANIEL MARK LAWRENCE
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 the charged in the information and that of the persons
arraigned are one and the same;
2. The identity of May Nicole Cruz, the victim;
3. The date and places of the commission of the crime.
EVIDENCE FOR MARKINGS
1. Affidavit of the security guard Jenie De leon
Purpose: to prove that she was on- patrol when the robbery took
place and that she was the one who responded to the incident

2. Affidavit of maid Lea Rosario

Purpose: to prove that she personally heard the noise of
breaking the door of the back door of the house and actually saw and
identified the face of the accused.
3. Affidavit of neighbor Dodong Romero
Purpose: to corroborate the testimonies of Jenie De Leon
and Lea Rosario
4. Affidavit of Koko Martin
Purpose
5. Blotter Report of Manila Police Station
Purpose: to prove that the police authority received a report
that a robbery took place at Maligaya Subdivision, located at Brgy 123,
Sampaloc Metro Manila.
6. CCTV footage camera of the Subdivision
7. Picklocks
ISSUES
1. Whether or not the accused committed the crime charged;
2. Whether or not the accused is guilty thereof.
WITNESSES
1. Jenie De leon to testify that a robbery took place;
2. Lea Rosario to testify that she were the maid who has personal knowledge
of the incident of robbery
3. Dodong Romero to testify that he was the neighbor of the victim.
4. Police Senior Inspector Aldrin Christian to testify that he conducted the
investigation in the crime scene recovering picklocks, fingerprints and hair
samples and to attest the veracity of his 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
Metro Manila, Manila, Philippines, September 16, 2016.

Manila City Prosecutors Office

Hall of Justice
Sampaloc Manila
By:
Ninz Berdonar
Assistant City Prosecutor
Roll no. 12345/ 6789
IBP. No. 1112/ 04-05-17
MCLE EXEMPT
PTR EXEMPT
Copy furnished:
ATTY. Rx Barrera
Counsel for the Defense
[A-D-D-R-E-S-S]
Received by: _______________
Date: _____________________

CERTIFICATION AGAINST NON-FORUM SHOPPING

REPUBLIC OF THE PHILIPPINES )
CITY OF MANILA
) S.S.
I, NINZ BERDONAR, of legal age, Filipino citizen, single and a
resident of San Mariano Isabella, after having been duly sworn to
in accordance with law do hereby depose and say:
That I am the petitioner in the above entitled case;
That I have caused the preparation of the forgoing complaint and
have read the allegations contained therein;
The allegation in the said complaint are true and correct of my
own knowledge and authentic records;
I hereby certify that I have not commenced any other action or
proceeding involving the same issues in the Supreme Court,
Court of Appeals or any other tribunals or agency;
That if I should thereafter learned that a similar action or
proceedings has been filed or is pending before the Supreme
Court, Court of Appeals or any other tribunals or agency, I hereby
undertake to report that fact within five (5) days therefrom to the
court or agency wherein the original pleading and sworn
certification contemplated herein have been filed;
I execute this certification to attest to the truth of the forgoing facts
and to comply with the provisions of Administrative Circular No.
04-94 of the Honorable Supreme Court.
IN WITNESS WHEREOF, I have hereunto affixed my signature
this ___ day of September 2016, in the City of Manila.
_______________
NINZ BERDONAR
Assistant City Prosecutor
Roll no. 12345/ 6789
IBP. No. 1112/ 04-05-17

MCLE EXEMPT
PTR EXEMPT