Republic of the Philippines

REGIONAL TRIAL COURT

Fourth Judicial Region Branch
Cagayan de Oro City

PEOPLE OF THE PHILIPPINES, CRIMINAL CASE NO. 1234567

Plaintiff,
FOR:
Violation of Anti-Bouncing
Check law
- versus -

HENRY CHAO,
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 accused EDUARDO LANKIN in the information
and that of the person arraigned is one and the same;
2. The identity of TED MAGNO, the victim;
3. The Court’s territorial jurisdiction relative to the offense charged;
4. The cause of death of the victim;
5. The date and place of the commission of the crime;
6. The genuineness and due execution of the documents.
 EVIDENCE FOR MARKINGS

1. Affidavit of the TED MICHAEL MAGNO

Purpose: to prove the commission of the crime by the accused

against the victim;

2. Affidavit of the PO1 ARVIE CHRISTOPHER SADILI

Purpose: to prove the date, place and other circumstances of the

commission of the crime;

3. Affidavit of customer ROSANNA MARIE MERGAL

Purpose: to corroborate the testimony of TED MICHAEL MAGNO

and PO1 ARVIE CHRISTOPHER SADILI;

4. Autopsy Report of EDGAR LANKIN issued by PAGAMUTANG

PANGMASA NG LAGUNA

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

ISSUES

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

2. Whether or not they were guilty thereof.

WITNESSES

1. TED MICHAEL MAGNO to testify that the crime took place;

2. PO1 ARVIE CHRISTOPHER SADILI to testify that he was the officer
on duty patrolling in the vicinity of the crime scene during its
commission;
3. ROSSANA MARIE MERGAL to testify that she was at the crime scene
during its commission.
 TRIAL DATES

Specifically all Fridays of the month, with the regular appearance

of the undersigned city prosecutor before this Honorable Court.

RESPECTFULLY SUBMITTED.
Calamba City, Laguna, Philippines, September 20, 2014.

CALAMBA CITY PROSECUTOR’S OFFICE

Ramon Q. Avanceña Hall of Justice
Bonifacio Drive, Calamba City

By:

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

Copy furnished:

ATTY. NESLEY CRUZ

Counsel for the Defense
Room 200, New Valentine Bldg.
Central Perpetual University
Lopez Jaena St., Rizal, Calamba City

Received by:___________
Date: ___________