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Republic of the Philippines

National Capital Judicial Region


REGIONAL TRIAL COURT
Branch 1
City of Manila

PEOPLE OF THE PHILIPPINES,


Plaintiff, CRIM. CASE NO.2017-111123
FOR: Viol. Section 11, Article 2
R.A. 9165
- versus -

NOEL CRUZ ALARCON,


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 identity of the one charged in the information and that of the person
arraigned are one and the same;
2. the date and places of the commission of the crime.

EVIDENCE FOR MARKINGS

1. Affidavit of the arresting officer


Purpose: to prove that a surveillance operation was conducted that led to the
arrest of one NOEL CRUZ ALARCON at his residence at 246 Walangbuhay
St., U.N. Avenue, Ermita, Manila;

2. Item confiscated
Purpose: to prove the existence of the Three (3) pieces small zip-locked
transparent plastic sachet containing white crystalline substance SHABU to
show the cause of action;
2. PNP Crime Laboratory result
Purpose: to prove that the white crystalline substance confiscated from the
suspect is methamphetamine or more popularly known as Shabu and to prove
that the confiscated substance from the suspect weight more or less 3 grams;

3. Affidavits of Ms. KARA DAVID, Barangay Captain; FLORA


Lola KapS. Borja-De Leon and Barangay Councilor ANJO YLLANA
Purpose: to prove that the arresting officers followed the PNP Operational
Manual on arresting the suspect and that the confiscated substance from the
suspect indeed came from him;

4. Blotter Report of MPD Station 1


Purpose: to prove that the police authority received a report that a suspect has
been arrested at 246 Walang Buhay St., U.N. Avenue, Ermita, Manila.

ISSUES

1. Whether or not the accused committed the crime charged;


2. Whether or not they were guilty thereof.

WITNESSES
1. Police Senior Inspector Ricardo Dalisay, the team leader of the
arresting team to prove that a valid surveillance and arrest of the suspect took
place;
2. Kara David, a media practitioner to prove that the arresting team
conducted the surveillance operation, arrest and proper processing of the
suspect;
3. Punong Barangay Flora Lola KapBorja-De Leon to prove a proper
coordination was made by the operating unit with the barangay officials of the
place where the arrest was made;
4. Kagawad Anjo Yllana to prove that coordination was made and the
confiscated substance came from the possession of the suspect;
5. Dra. Carolina Garcia to testify that she conducted the laboratory
examination of the confiscated substance and the final result thereof after
undergoing laboratory chemistry.

TRIAL DATES

Specifically all Fridays of the month, with the regular appearance of the
undersigned city prosecutors before this Honorable Court.

RESPECTFULLY SUBMITTED.

City of Manila, Philippines, July 4, 2017.

CITY OF MANILA PROSECUTORS


OFFICE

By:
JO-AN C. PABLO
Assistant City Prosecutor
Roll No. 91234 / 5-2-20
IBP. No. 912345 / Lifetime
MCLE Exempt
PTR Exempt

JHAMEL P. BANSAO
Assistant City Prosecutor
Roll No. 91123 / 5-4-19
IBP No. 667900 / Lifetime
MCLE Exempt
PTR Exempt
Copy furnished:

ATTY. ELISEO J. SALVADOR, JR.


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

Received by:___________
Date: __________