Republic of the Philippines

National Capital Judicial Region

REGIONAL TRIAL COURT
Branch___
Manila city
PEOPLE OF THE PHILIPPINES,
Plaintiff,

CRIMINAL CASE NO._______

FOR:
ROBBERY WITH HOMICIDE

- versus MARK MAANGAS,

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 ADIC ADICTU, 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 JANE MALAS
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 GAN GANDA
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 ABY PRETI
Purpose: to corroborate the testimonies of JANE MALAS and GAN GANDA;
3. Autopsy Report of ADI ADICTU 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 MANILA Police Station
Purpose: to prove that the police authority received a report that a robbery took
place at savemore, located at Taft Manila City.

5. Affidavit of RIN NIG

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 victims body was shot and the nature,
extent and location of wound.
8. Ballistics Test result
Purpose: To prove that the slug recovered from the victims body came from the
same gun which was recovered from the possession of BAR RIL.
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. JANE MALAS to testify that a robbery took place;
2. GAN GANDA to testify that she was one of the customers of the Iloilo
Supermart at the time the robbery took place;
3. ABY PRETI

to testify that she was one of the customers of Iloilo

Supemart at the time the robbery took place.

4. POL TUL to testify that he was the police officer who went to the scene
of the crime and arrested the accused.
5. Dra. SABEL GAL 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 POUL POL to testify that he conducted the
ballistics examination and to attest to the veracity of his findings in the said
report.
7. Chemist GIL MANG 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.
MANILA CITY, Iloilo, Philippines, February 24, 2015.

MANILA CITY PROSECUTORS OFFICE

ROCKY PANALO Hall of Justice
TAFT,MANILA City

By:
TALO PALO
Assistant City Prosecutor
Roll No.
IBP. No.
MCLE Exempt
PTR Exempt

And

OLAT TALO

Copy furnished:
ATTY. PANALO WIN
Counsel for the Defense
ESPANYA MANILA CITY
Received by:___________
Date: ___________

Assistant City Prosecutor

Roll No
IBP NoMCLE Exempt
PTR Exempt