REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

CITY OF MAKATI

BRANCH 1

PEOPLE OF THE PHILIPPINES,

Plaintiff,

-versus- CRIMINAL CASE NO.123456

FOR: Murder

JUAN TAMBAY,

Accused.

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PRE-TRIAL BRIEF OF THE PROSECUTION

THE PEOPLE OF THE PHILIPPINES, through the undersigned CityProsecutor, before this Honorable
Court, most respectfully submit this Pre-TrialBrief:

SUMMARY OF ADMITTED FACTS AND PROPOSED STIPULATION OF FACTS

The following are the admitted facts:

1. the identities of the person charged in the information and that of the person arraigned are
one and the same;

2. the identity of Pedro Masipag, 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 witness Diego Tagamasid

Purpose: to prove that he was standing outside of his house a few meters when the defendant
approached the victim and fired three gunshots fatally wounding the victim.
3. Autopsy Report of Pedro Masipag issued by Ospital ng Makati

Purpose: to prove the extent of the injury and the cause of death of the victim;

4. Blotter Report of Makati Police Station

Purpose: to prove that the police authority received a report of the shooting that took place.

WITNESSES

1. Diego Tagamasid to testify that he saw the actual shooting of the victim;

2. SPO2 Ricardo Dalisay to testify that he was the lead investigator who responded to the
shooting incident

3. Dra. Sonia Malusog to to testify that she performed the autopsy conducted on the body of the
victim.

TRIAL DATES

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

RESPECTFULLY SUBMITTED.

Makati City, Philippines, June 20, 2018.

MAKATI CITY PROSECUTOR’S OFFICE

By:

CHRISTIAN FRANCO

Assistant City ProsecutorRoll No. 12345 / 5-2-07IBP. No. 667899 / 12-29-07MCLE ExemptPTR
Exempt

Copy furnished:

ATTY. ENRICO PONCE

6th Floor Madrigal Center Tower,Muntinlupa City.

Attorney’s Roll No.23456

IBP No.012345/May 7,2015/Muntinlupa City

PTR No.567890/May 15,2015/Muntinlupa City

MCLE No.123456/ April 20, 2015.