Prosecution

SCRIPT Frustrated Murder
PROSECUTOR ANTHONY PRESTOZA: For the government.
People vs. Merin
ATTY. TAPIRE: For the defense.
CHARACTERS:
COURT: Ready?
Ayn Sarsaba -Prosecution Counsel
PROSECUTOR ANTHONY PRESTOZA: Ready Your Honor.
Anthony Prestoza - Prosecution Counsel
COURT: Call your witness to the witness stand.
Katherine Jane Manarang -Complainant
PROSECUTOR ANTHONY PRESTOZA: May I call on Catherine Jane Manarang.
Richard Alvin Nalupta- Boyfriend of the Complainant (Prosecution Witness)

Dr. Juan Paolo Gascon -Expert Witness
INTERPRETER: Do you swear to tell the truth, all the truth and nothing but the
truth in this case?
Analita Ocampo -Defense Counsel
WITNESS: Yes, sir.
Helen Paulette Tapire- Defense Counsel
COURT: Please state your name and other personal circumstances.
Iris Victoria Merin - Accused

Leira Taruc- Expert Witness
Catherine Bool- Nunez -Officemate of Complainant (Defense Witness)
PROSECUTION
MANARANG
PRESTOZA
COURT: Call the case.

INTERPRETER: For hearing, Criminal Case No. 12345, People of the Philippines
vs. Iris Victoria Merin.
COURT: Appearances.
WITNESS: Catherine Jane Manarang, 28 years of age, single, a Certified Public

Accountant of the Accounting Division of Nestle Philippines and a resident of Unit
143 Astral Apartment Padre Faura St. Ermita, Manila.
COURT: Your witness.
Joel Macalino
DIRECT EXAMINATION OF CATHERINE JANE

(COMPLAINANT)
BY
PROSECUTOR
ANTHONY
(PROSECUTION COUNSEL)
COURT: Swear in the witness.
PROSECUTOR ANTHONY PRESTOZA: The witness is being presented to testify

on the fact that the accused bought the rat killer and that the substance that poisoned
her was from the grapefruit juice which the accused prepared. May we proceed Your
Honor?
COURT: Proceed.
PROSECUTOR ANTHONY PRESTOZA: Catherine Jane Manarang, will you
please tell this Honorable Court where you were on October 17, 2007 at around 8
oclock in the morning?
CATHERINE JANE MANARANG: I was in our apartment at Unit 143 Astral

Apartment Padre Faura St. Ermita, Manila.
PROSECUTOR ANTHONY PRESTOZA: Who lives in that apartment?
CATHERINE JANE MANARANG: I and my best friend, Iris Victoria Merin.
PROSECUTOR ANTHONY PRESTOZA: Who was with you at that particular
time of the day?
CATHERINE JANE MANARANG: I was alone because I did not report for work
to prepare for my engagement party.
PROSECUTOR ANTHONY PRESTOZA: How did you prepare for the party?
CATHERINE JANE MANARANG: I decided to clean the house.
PROSECUTOR ANTHONY PRESTOZA: And what particular areas of the house
did you clean?
CATHERINE JANE MANARANG: I cleaned the living room and the CR first.
Then I cleaned the dirty kitchen. Because I remembered Iris said something like
Dumadami na yung mga rodents sa dirty kitchen.
PROSECUTOR ANTHONY PRESTOZA: Have you actually seen any rats in your
place? A: No. Actually, it made me wonder I just relied on the word of Iris. Besides,
in our lease agreement, there was a stipulation that it shall be the owners
responsibility to conduct quarterly pest control measures.
PROSECUTOR ANTHONY PRESTOZA: I am showing to you this document
previously marked as Exhibit A. Please go over this document and tell this Honorable
Court if this is the lease agreement you are referring to.
CATHERINE JANE MANARANG: Yes, this document is the lease agreement.
PROSECUTOR ANTHONY PRESTOZA: Whose signature is this above the
printed name Catherine Jane Manarang which is appearing on page 2 of this contract
of lease?
CATHERINE JANE MANARANG: My signature, sir.
PROSECUTOR ANTHONY PRESTOZA: And this signature belongs to whom?
(Prosecutor Prestoza pointing at the right portion of the document)
CATHERINE JANE MANARANG: Our lessor, Mr. Rhandell Matuloy.
PROSECUTOR ANTHONY PRESTOZA: The last place you cleaned was the dirty
kitchen?
PROSECUTOR PRESTOZA: Which for purposes of identification, Your Honor, I

would like to request the marking of the signature appearing above the printed name
of Catherine Jane Manarang as Exhibit A-1.
CATHERINE JANE MANARANG: Yes, Your Honor.
COURT: Mark it.
PROSECUTOR ANTHONY PRESTOZA: What did you do in order to solve the

problem on the rats?
PROSECUTOR ANTHONY PRESTOZA: And the signature appearing above the

printed name of Rhandell Matuloy as the lessor be marked as Exhibit A-2.
CATHERINE JANE MANARANG: I used a rat killer, Your Honor.
COURT: Mark it.
PROSECUTOR ANTHONY PRESTOZA: Who bought the rat killer?
PROSECUTOR ANTHONY PRESTOZA: We would also like to request for the

marking of stipulation no.8 in this lease agreement as Exhibit A-3.
CATHERINE JANE MANARANG: Iris bought it because she told me that she
noticed that there were rats in the place.
COURT: Mark it.
PROSECUTOR ANTHONY PRESTOZA: Was there consistent compliance by the

owner?
CATHERINE JANE MANARANG: Yes.
PROSECUTOR ANTHONY PRESTOZA: What happened next?
CATHERINE JANE MANARANG: After cleaning, I rested because I got tired. I
remembered that before Iris left that morning for work, she told me not to forget to
drink the grapefruit juice she prepared for me.
PROSECUTOR ANTHONY PRESTOZA: Where did you find the grapefruit juice?
CATHERINE JANE MANARANG: Inside the ref.
PROSECUTOR ANTHONY PRESTOZA: If that pitcher containing the grapefruit
juice will be shown to you, will you be able to recognize it? (lawyer takes the pitcher
showing it to the victim)
PROSECUTOR ANTHONY PRESTOZA: What else did you do on that day?

CATHERINE JANE MANARANG: I went out to meet Iris for our usual coffee
break in Starbucks at 3 oclock in the afternoon. We spent the whole afternoon
together until we decided to go home for the party.
PROSECUTOR ANTHONY PRESTOZA: Did you feel anything at that time?
ATTY. OCAMPO: Objection, Your Honor! Question is leading.
COURT: Sustained.
PROSECUTOR ANTHONY PRESTOZA: What happened at Starbucks?
CATHERINE JANE MANARANG: While were eating, I complained to Iris that
my head was aching.
PROSECUTOR ANTHONY PRESTOZA: Did your friend say anything?
CATHERINE JANE MANARANG: Yes, thats the one.
CATHERINE JANE MANARANG: She told me that I was just tired.
PROSECUTOR ANTHONY PRESTOZA: For the record, the pitcher, previously

marked as Exhibit B was recognized by the victim as the pitcher containing the
grapefruit juice prepared by the accused for the complainant.
PROSECUTOR ANTHONY PRESTOZA: What time did you leave Starbucks?
PROSECUTOR ANTHONY PRESTOZA: When did you drink the said beverage?
CATHERINE JANE MANARANG: Before I went to Starbucks.
PROSECUTOR ANTHONY PRESTOZA: How many glasses were you able to
drink?
CATHERINE JANE MANARANG: 5 oclock

PROSECUTOR ANTHONY PRESTOZA: What time did you arrive in your
apartment?
CATHERINE JANE MANARANG: We arrived at about 5:30 oclock in the late
afternoon. The dinner party was set at 6 oclock that evening.
PROSECUTOR ANTHONY PRESTOZA: What happened later?
CATHERINE JANE MANARANG: I drank about 2 glasses.
CATHERINE JANE MANARANG: The guests arrived. We entertained them.
PROSECUTOR ANTHONY PRESTOZA: Can you estimate the amount of juice

you drank?
PROSECUTOR ANTHONY PRESTOZA: Was your fiance with them?
CATHERINE JANE MANARANG: A glass would contain about 300-350 mL of

liquid. So, that would make about 600-700 mL.

PROSECUTOR ANTHONY PRESTOZA: What happened next?
CATHERINE JANE MANARANG: I approached Iris and chatted with her.

PROSECUTOR ANTHONY PRESTOZA: What did you feel at that time?
CATHERINE JANE MANARANG: My headache worsened. I began to feel
nauseous and I vomited. I felt so weak that I lost my balance.
ATTY. ANALITA OCAMPO: And during what months did the lessor conduct these
pest control measures?
CATHERINE JANE MANARANG: February, May, August, and November of
every year, Your Honor.
PROSECUTOR ANTHONY PRESTOZA: Did anyone come to help?
ATTY. ANALITA OCAMPO: Miss Witness, you testified that in cleaning the dirty
kitchen, you used a rat poison to kill the rats there. Is that right?
CATHERINE JANE MANARANG: Yes, Iris caught me before I hit the floor.
PROSECUTOR ANTHONY PRESTOZA: Did you notice anything else?
ATTY. ANALITA OCAMPO: How did you use the rat poison?
CATHERINE JANE MANARANG: Before I totally lost consciousness, I saw that

Iris was smiling while she held on to me.
CATHERINE JANE MANARANG: I took the pack out of the box. Then I put some
into my hand. I put the rat poison in some rice and then I put the rice on the floor so
that the rats could eat them.
PROSECUTOR ANTHONY PRESTOZA: So, if the accused is inside this

courtroom, would you be able to identify and point to her?
CATHERINE JANE MANARANG: Yes, Sir. (Victim pointed to the accused.)
There.
PROSECUTOR ANTHONY PRESTOZA: That is all, Your Honor.
ATTY. ANALITA OCAMPO: You did not use any gloves to protect your hands or
your skin?
CATHERINE JANE MANARANG: No, Your Honor.
COURT: Cross?
ATTY. ANALITA OCAMPO: Miss Witness, did you know that a rat poison could
also poison humans if accidentally swallowed?
ATTY. OCAMPO: Yes, Your Honor.
CROSS EXAMINATION OF CATHERINE JANE

MANARANG(COMPLAINANT) BY ATTY. ANALITA OCAMPO( DEFENSE
COUNSEL)
ATTY. ANALITA OCAMPO: Miss Witness, you testified that in the lease contract,
the lessor had the responsibility to conduct pest control measures. How often is this
pest control conducted?
CATHERINE JANE MANARANG: Quarterly, Your Honor.
ATTY. ANALITA OCAMPO: So, even if you knew that, you still did not use any
protection for your hands?
CATHERINE JANE MANARANG: Yes, because I planned to wash my hands after
I cleaned the dirty kitchen.
ATTY. ANALITA OCAMPO: After cleaning the dirty kitchen?
ATTY. ANALITA OCAMPO: Not right after you put the poison into the rice, as you
have said earlier?

ATTY. ANALITA OCAMPO: You testified that you drank the grapefruit juice. What
was the color of the juice?
CATHERINE JANE MANARANG: Yellow.
ATTY. ANALITA OCAMPO: When you drank the juice, what was its taste?
CATHERINE JANE MANARANG: It was sour, a bit bitter, Your Honor.
ATTY. ANALITA OCAMPO: Bitter?
ATTY. ANALITA OCAMPO: Hindi ka ba nagtaka at mapait yung juice na ininom
mo?
PROSECUTOR PRESTOZA: Objection: Your Honor! My witness cannot
understand Filipino.
COURT: Let the question be translated for the witness.
INTERPRETER: Did you not wonder why the juice was bitter?
ATTY. ANALITA OCAMPO: You testified that at 3 pm on October 17, 2007 you
met with the accused at a coffee shop. When you were with the accused, did you
notice anything different about her?
ATTY. ANALITA OCAMPO: What was that?
CATHERINE JANE MANARANG: When I complained about my headache, she
just told me that I was just tired.
ATTY. ANALITA OCAMPO: Were you not really tired after cleaning the entire
house?
CATHERINE JANE MANARANG: Yes, I was quite tired, Your Honor.
ATTY. ANALITA OCAMPO: You also said that at the party you felt nauseous, and
then you vomited and fell to the floor. Is that right?
ATTY. ANALITA OCAMPO: When you were already at the floor, were you still
conscious?
CATHERINE JANE MANARANG: No, Your Honor. The grapefruit juice really
has a slight bitter taste, perhaps because it was so sour.
ATTY. ANALITA OCAMPO: You testified that before the accused left the house,
she told you not to forget to drink the juice. Has she done this even before the
incident happened?
CATHERINE JANE MANARANG: A bit blurry, Your Honor.
CATHERINE JANE MANARANG: Yes, Your Honor. Both of us used to do that.

We often leave food and drinks for each other.
ATTY. ANALITA OCAMPO: Was your sight still clear?
ATTY. ANALITA OCAMPO: So you cannot see clearly at the time you fell to the
ground?
CATHERINE JANE MANARANG: Yes, because I was so dizzy.
ATTY. ANALITA OCAMPO: So, when she told you not to forget to drink the juice,
it was nothing new to you, because both of you had that habit.
ATTY. ANALITA OCAMPO: So you cannot possibly say that Iris was really
smiling when she held you?
CATHERINE JANE MANARANG: Im not sure Your Honor.
ATTY. ANALITA OCAMPO: Miss Witness, have you ever visited a psychiatrist?
ATTY. ANALITA OCAMPO: For the record, the complainant has identified Exhibit
1 which was previously marked as Summary Discharge Report at the Medical Center
Manila.
ATTY. ANALITA OCAMPO: When was this?
ATTY. ANALITA OCAMPO: Who prepared this medical report?
CATHERINE JANE MANARANG: Around August 2006, Your Honor.

ATTY. ANALITA OCAMPO: Why did you go to such psychiatrist?
CATHERINE JANE MANARANG: It was Dr. Taruc who prepared the report, Your
Honor.
CATHERINE JANE MANARANG: I needed treatment for my depression, Your

Honor.
ATTY. ANALITA OCAMPO: Miss Witness, did anything happen before you visited
your psychiatrist?
ATTY. ANALITA OCAMPO: What was the cause of your depression?
CATHERINE JANE MANARANG: I committed suicide.
CATHERINE JANE MANARANG: My parents died of a terrible accident, and I

blamed myself for their death.
ATTY. ANALITA OCAMPO: Did your psychiatrist prescribe any medication?
ATTY. ANALITA OCAMPO: Who was the doctor who treated you?
ATTY. ANALITA OCAMPO: Are you still taking these medications?
CATHERINE JANE MANARANG: Dr. Leira Taruc.
CATHERINE JANE MANARANG: Not anymore, Your Honor.
ATTY. ANALITA OCAMPO: Where is her clinic located?
ATTY. ANALITA OCAMPO: No further questions.
CATHERINE JANE MANARANG: At the Medical Center Manila.
COURT: Re-direct?
ATTY. ANALITA OCAMPO: What did this Dr. Taruc do to treat you?
PROSECUTOR PRESTOZA: No, Your Honor. We will call on our next witness.
CATHERINE JANE MANARANG: I went through psychological counseling

sessions, Your Honor.
COURT: Miss Witness, You may step down. Call your next witness.
ATTY. ANALITA OCAMPO: Were this counseling sessions reduced into writing?
DIRECT EXAMINATION OF RICHARD NALUPTA (BOYFRIEND OF THE

COMPLAINANT PROSECUTION WITNESS) BY PROSECUTOR ANTHONY
PRESTOZA (PROSECUTION COUNSEL)

ATTY. ANALITA OCAMPO: Is this document the record of the treatment you went
through under Dr. Taruc? (Atty. Ocampo showing the summary discharge report to
the complainant)
CATHERINE JANE MANARANG: Yes, Your Honor
CATHERINE JANE MANARANG: Yes, she gave me anti-depressant pills.
PROSECUTOR ANTHONY PRESTOZA: Im calling on Mr. Richard Alvin

Nalupta.
truth in this case?
RICHARD NALUPTA: Yes Sir.

RICHARD NALUPTA: Ritchie Nalupta, 30 years of age, single, head security
officer of the Security Services Division of Nestle Philippines and a resident of 299
Aguado St. San Miguel Quiapo, Manila.
PROSECUTOR ANTHONY PRESTOZA This witness, Your Honor, Richard
Nalupta is presented to testify on the fact that the accused secretly fell in love and
could possibly be obsessed with him and may likewise began to hate the complainant
secretly. May we proceed, Your Honor?
COURT: Proceed.
PROSECUTOR ANTHONY PRESTOZA: Do you visit the complainant in their

apartment?
RICHARD NALUPTA: Yes, Your Honor.
PROSECUTOR ANTHONY PRESTOZA: How often do you visit the
complainant?
RICHARD NALUPTA: During weekdays, whenever I drop her after work, and
during weekends.
PROSECUTOR ANTHONY PRESTOZA: Whenever you visit the complainant in
their apartment, are there any persons around?
RICHARD NALUPTA: Yes, sometimes, Iris was there.
PROSECUTOR ANTHONY PRESTOZA: Do you know the complainant?
PROSECUTOR ANTHONY PRESTOZA: When you visit the complainant during

weekend, was the complainant always there?
RICHARD NALUPTA: Yes.
RICHARD NALUPTA: Not always, Your Honor.
PROSECUTOR ANTHONY PRESTOZA: How are you related to her?
PROSECUTOR ANTHONY PRESTOZA: What do you mean when you said that
the complainant was not always there?
RICHARD NALUPTA: She is my fianc.

PROSECUTOR ANTHONY PRESTOZA: Do you know the accused?
RICHARD NALUPTA: Shes not there because she went out.
RICHARD NALUPTA: Yes.
PROSECUTOR ANTHONY PRESTOZA: And whenever that happens, who do

you find at their apartment?
PROSECUTOR ANTHONY PRESTOZA: How is she related to the complainant?
RICHARD NALUPTA: Iris, Your Honor.
RICHARD NALUPTA: She is the childhood friend of the complainant; officemate;

and they live in the same apartment.
PROSECUTOR ANTHONY PRESTOZA: Mr. Witness, what do you do whenever

you visit the complainant at their apartment and she is not around?
PROSECUTOR ANTHONY PRESTOZA: Were you aware that the accused likes
you?
RICHARD NALUPTA: I wait for her to come back, Your Honor.
ATTY. OCAMPO: Objection, Your Honor. Counsel is speculating.
PROSECUTOR ANTHONY PRESTOZA: Where or in what particular part of the

apartment do you wait?
RICHARD NALUPTA: At the living room, Your Honor.

PROSECUTOR ANTHONY PRESTOZA: And while waiting, what normally
transpires?
PROSECUTOR ANTHONY PRESTOZA: Does your fianc know of these

instances?
RICHARD NALUPTA: I watch the tv or listen to music.
PROSECUTOR ANTHONY PRESTOZA: Why?
PROSECUTOR ANTHONY PRESTOZA: You said earlier that whenever the

complainant is not around during your visit, Iris was at the apartment, is that right?
RICHARD NALUPTA: Because I told her a few times about it.

PROSECUTOR ANTHONY PRESTOZA: So there were times that only you and
the accused were in the apartment, while you were waiting for the complainant?
PROSECUTOR ANTHONY PRESTOZA: What did your fianc say?

RICHARD NALUPTA: She said: Dont mind her. Shes crazy.
PROSECUTOR ANTHONY PRESTOZA: Mr. Witness, please examine this text
message, and tell the Court if you recognize it?
PROSECUTOR ANTHONY PRESTOZA: What transpires whenever you and the

accused are alone in the apartment?
PROSECUTOR ANTHONY PRESTOZA: Why do you recognize it?
RICHARD NALUPTA: The accused flirts with me, Your Honor.
RICHARD NALUPTA: Because I received that text message from the accused on
August 15, 2007.
PROSECUTOR ANTHONY PRESTOZA: What do you mean when you said she
was flirting with you?
RICHARD NALUPTA: She wears revealing clothes, she says I love you jokingly,
mga ganun.
PROSECUTOR ANTHONY PRESTOZA: This text message purports to have been

sent by the person owning this mobile number, 09173237890. Do you recognize the
person who owned this number?
RICHARD NALUPTA: Yes, that is the mobile number of the accused, Your Honor.
PROSECUTOR ANTHONY PRESTOZA: Do you recall how many times these

have happened?
PROSECUTOR ANTHONY PRESTOZA: How do you know?
RICHARD NALUPTA: Many times, Your Honor.
RICHARD NALUPTA: Because the mobile number of the accused is stored in my

mobile phone, Your Honor.
PROSECUTOR ANTHONY PRESTOZA: What do you tell the accused every time
she flirts with you?
RICHARD NALUPTA: I dont mind her jokes.
PROSECUTOR ANTHONY PRESTOZA: Will you please read aloud the contents
of this text message?
RICHARD NALUPTA: Richie, kung hindi ka magiging akin, walang makikinabang
sayo! (Richie, if I wont have you, no one else will)
PROSECUTOR ANTHONY PRESTOZA: Mr. Witness, kindly read the next text
message.
RICHARD NALUPTA: Akin ka lang, Richie. Mamamatay ang kahit sinong aagaw
sayo. (Youre mine, Richie. Whoever tries to steal you from me will die.)
PROSECUTOR ANTHONY PRESTOZA: What did you do afterwards?

RICHARD NALUPTA: I called for an ambulance. We rushed her to the hospital.
PROSECUTOR ANTHONY PRESTOZA: How long did you stay with her at the
hospital?
PROSECUTOR ANTHONY PRESTOZA: Your Honor, for the record, these text
messages appearing on the screen of the mobile phone of Mr. Nalupta, previously
marked as Exhibit C has been identified by the witness.
RICHARD NALUPTA: About four hours. I waited for the doctor to come out.
PROSECUTOR ANTHONY PRESTOZA: This document is the printed copy of

the text messages contained in the mobile phone of Mr. Nalupta. We would like to
request that it be marked as Exhibit C-1.
RICHARD NALUPTA: The doctor said my fiance was poisoned.
COURT: Mark it.

PROSECUTOR ANTHONY PRESTOZA: How often does she send you this kind
of text messages?
RICHARD NALUPTA: Almost everyday, Your Honor.
PROSECUTOR ANTHONY PRESTOZA: What were you doing during the
engagement party?
PROSECUTOR ANTHONY PRESTOZA: When the doctor came out, what did he
tell you?
PROSECUTOR ANTHONY PRESTOZA: No further questions, Your Honor.

COURT: Cross?
ATTY. OCAMPO: Yes, Your Honor
CROSS EXAMINATION OF RICHARD NALUPTA (BOYFRIEND OF THE
COMPLAINANT /PROSECUTION WITNESS) BY ATTY. ANALITA
OCAMPO (DEFENSE COUNSEL)
RICHARD NALUPTA: I was entertaining our friends.
ATTY. ANALITA OCAMPO: Mr. Witness, you have testified that whenever you
and Ms. Merin are alone in the apartment, she tried to flirt with you. Is that right?
PROSECUTOR ANTHONY PRESTOZA: Were you near the victim?
RICHARD NALUPTA: No. I was about 8 meters away from her.
ATTY. ANALITA OCAMPO: What made you say that?
PROSECUTOR ANTHONY PRESTOZA: Who was with the victim when the
incident happened?
RICHARD NALUPTA: Well, I feel she made some advances. ( extra sweetness )
RICHARD NALUPTA: She was with the accused.

PROSECUTOR ANTHONY PRESTOZA: What did you do when you learned of
the incident?
RICHARD NALUPTA: I rushed to her. She was already lying on the ground.
ATTY. ANALITA OCAMPO: How long have you known Ms. Merin?
RICHARD NALUPTA: I have known her ever since I began courting my fiance
since both of them live in the same apartment. Thats about four years ago.
ATTY. ANALITA OCAMPO: Would you consider Ms. Merin as your friend?
RICHARD NALUPTA: Ummm. Yes.

ATTY. ANALITA OCAMPO: Mr. Witness, is it possible that the reason why Ms.
Merin treats you well and with extra sweetness is because she considers you as a
close friend since you are the fiance of her best friend?
RICHARD NALUPTA: Yes
DIRECT EXAMINATION OF DR. JUAN PAOLO GASCON (Expert Witness)

BY PROSECUTOR AYN SARSABA (Prosecution Counsel)
PROSECUTOR AYN SARSABA: Im calling on Dr. Juan Paolo Gascon.
truth in this case?
ATTY. ANALITA OCAMPO: You also testified that Ms. Merin sent you threatening
text messages. What is you proof that it was indeed my client who sent you those
messages?
DR. JUAN PAOLO GASCON :Yes.
RICHARD NALUPTA: I am sure Your Honor because I am familiar with the way
she constructs her messages.
DR. JUAN PAOLO GASCON Dr. Juan Paolo Gascon, 28 years of age, single,
emergency physician and a resident of Robinsons Tower, Padre Faura St., Ermita,
Manila.
ATTY. ANALITA OCAMPO: Mr. Witness, does the complainant use your mobile
phone in sending text messages to her friends?
RICHARD NALUPTA: Yes, sometimes

ATTY. ANALITA OCAMPO: How about you? Are there times when you borrow
the complainants cellular phone?
RICHARD NALUPTA: Yes, there are times I use her phone.
ATTY. ANALITA OCAMPO: So, is it possible that Ms. Merins phone has also
been borrowed by someone else and it was not her who sent you those text messages?
PROSECUTOR AYN SARSABA: This witness, Your Honor, Dr. Juan Paolo
Gascon, will testify on the findings in the medico-legal report prepared by him to
prove the following:
(i) that the effective cause of the complainants condition is chemical poisoning;
(ii) that the dose taken by the complainant is necessarily fatal; and
(iii) that the possible source of the cyanide poison is the grape fruit juice prepared by
the accused. May we proceed, Your Honor?
RICHARD NALUPTA: Yes its possible. But Your Honor Im really sure she was the
one who sent me those messages.
COURT: Proceed.
ATTY. ANALITA OCAMPO: No further questions, Your Honor.
PROSECUTOR AYN SARSABA: You declared that you are a doctor of medicine,
Dr. Gascon, where did you finish your medical degree?
COURT: Re-direct?
PROSECUTOR PRESTOZA: No, Your Honor. We will call on our last witness.
DR. JUAN PAOLO GASCON: Emilio Aguinaldo College, United Nations Avenue,
Manila.
COURT: Call your witness.
PROSECUTOR AYN SARSABA: When did you graduate?
DR. JUAN PAOLO GASCON: 1994?

PROSECUTOR AYN SARSABA: Are you a licensed physician?
January in Florida, USA entitled Emergency Medicine: Practicing According to the

Evidence.
DR. JUAN PAOLO GASCON: Yes.
PROSECUTOR AYN SARSABA: Have you testified as a Medical expert in cases

before courts of justice?
PROSECUTOR AYN SARSABA: When did you pass the doctors board
examination?
DR. JUAN PAOLO GASCON: Yes, mostly on medico legal cases.
DR. JUAN PAOLO GASCON: in 1995.
PROSECUTOR AYN SARSABA: How many medico legal cases so far have you
testified? What kind of medico legal cases have you testified?
PROSECUTOR AYN SARSABA: Where are you presently connected?

DR. JUAN PAOLO GASCON: Im presently connected with the Philippine General
Hospital located in Taft, Manila.
DR. JUAN PAOLO GASCON: For the past 5 years, around two hundred (200)
cases. Mostly homicide and murder cases involving food and chemical poisoning,
medical malpractice cases and industrial and vehicular accidents.
PROSECUTOR AYN SARSABA: Since when have you been employed in that
hospital?
PROSECUTOR AYN SARSABA: Do you recall having attended on one Catherine

Jane Manarang at the Philippine General Hospital?
DR. JUAN PAOLO GASCON: I have been employed there since 1998.
PROSECUTOR AYN SARSABA: What is your present designation?
PROSECUTOR AYN SARSABA: Do you recall when was that doctor? About what
time?
DR. JUAN PAOLO GASCON: Im presently an emergency physician in said

institution.
DR. JUAN PAOLO GASCON: About 6:30 in the evening of October 17, 2007.
PROSECUTOR AYN SARSABA: Since you became a licensed physician, have you
attended seminars and undertaken training in connection with the practice of
medicine? When and where?
PROSECUTOR AYN SARSABA: Do you recall how many days was she confined
to the hospital?
DR. JUAN PAOLO GASCON: Yes. I have attended several training seminars on
emergency medicine held here and abroad. In fact, I have also been invited as a guest
speaker to give special lectures on modern medical toxicology and the medico-legal
aspect of poisoning. To name a few: One of the international medical conferences
Ive attended was in Switzerland last October 2007 called Poisoning and Drug
Overdose by Dr. Barry Rumack and Dr. Allan Hall who were internationally
recognized experts in internal medicine. Another would be the one held just last
PROSECUTOR AYN SARSABA: Why was she confined that long?
DR. JUAN PAOLO GASCON: She was confined for one week.
DR. JUAN PAOLO GASCON: We made sure that the neurologic and
cardiovascular status has normalized and acidosis and other metabolic abnormalities
have resolved before we discharged her.
PROSECUTOR AYN SARSABA: While in the hospital, did you continue attending
on her? A: Yes. Q: After her discharge, did you require her to still see you for further
medications?
A: Yes, Your Honor.
PROSECUTOR AYN SARSABA: Why?
DR. JUAN PAOLO GASCON: I advised the patient to have a follow-up within 7 to
10 days after discharge to reevaluate and monitor for onset of delayed neurologic
manifestations.
PROSECUTOR AYN SARSABA: Did the patient see you for a follow-up Doctor?
PROSECUTOR AYN SARSABA: Did you find any neurologic complications in
said follow-up?
DR. JUAN PAOLO GASCON: None.
PROSECUTOR AYN SARSABA: So Doctor, we are assured that the patient,
complainant herein, is in a healthy state of mind?
PROSECUTOR AYN SARSABA: Attached to the record of the case is a Medico
Legal Report issued by one Dr. Juan Paolo Gascon, is this the one you are referring
to? (Exhibit D)
PROSECUTOR AYN SARSABA: For the record, the witness has identified the
document previously marked as Exhibit D as the Medico Legal Report issued by Dr.
Juan Paolo Gascon.
PROSECUTOR AYN SARSABA: There is a signature above the typewritten name
Dr. Juan Paolo Gascon, do you know whose signature is this doctor?
DR. JUAN PAOLO GASCON: It is my signature.

PROSECUTOR AYN SARSABA: I respectfully request Your Honor, that the
signature appearing in Exhibit D be marked as Exhibit D-1.
COURT: Mark it.
PROSECUTOR AYN SARSABA: Doctor, please read this particular entry. (Witness
reading a portion of the medico legal report)
DR. JUAN PAOLO GASCON: The patient came in the emergency room stretcherborne, unconscious and in respiratory distress. Her vital signs then were: Blood
pressure 80/50 mmHg, Cardiac rate of 50 beats per minute, Respiratory Rate of 12
cycles per minute and temperature of 37.8 degree Celsius. Patients skin was flushed.
PROSECUTOR AYN SARSABA: Could you please explain this finding in more
simple terms for an ordinary person to understand?
DR. JUAN PAOLO GASCON: The patient clearly was in an unstable condition, or
in a very critical condition, warranting an immediate medical intervention, constant
monitoring for any sign of deterioration and further evaluation.
PROSECUTOR AYN SARSABA: Do you know what could have caused this kind
of condition?
DR. JUAN PAOLO GASCON: My diagnosis at that time was there was chemical
poisoning.
PROSECUTOR AYN SARSABA: Why is the condition of Catherine Jane
Manarang attributable to poisoning rather than to disease or some natural cause? Were
tests conducted confirming the existence of poisoning?
DR. JUAN PAOLO GASCON: We did Toxin Screening with the patients blood. It
revealed the presence of trace amounts of cyanide in the blood, and since cyanide is
not normally found in our blood and considering its chemical nature, it is poisonous.
PROSECUTOR AYN SARSABA: So you are saying that the actual or effective
cause of the condition of the patient s
DR. JUAN PAOLO GASCON: Chemical poison, which is harmful to the body or
deadly to humans.
PROSECUTOR AYN SARSABA: Did the symptoms which appear resemble the
typical symptoms of poisoning by the alleged poison?
DR. JUAN PAOLO GASCON: Yes. The symptoms of cyanide poisoning are
headache, nausea, vomiting, generalized body weakness, loss of consciousness,
flushed skin, and unstable vital signs all of which are present in this case.
PROSECUTOR AYN SARSABA: Doctor, what could be a possible source of
cyanide in this case?
DR. JUAN PAOLO GASCON: Based on the history given to me by the informant
when the patient was brought to the ER, possible sources of cyanide could be any of
the food or beverage the patient had ingested on the day of the incident.
PROSECUTOR AYN SARSABA: History? What do you mean by that Doctor?
DR. JUAN PAOLO GASCON: We fill out a form called History and Physical
Examination. Contained here are the General Data, Reason for the Consult or Chief
Complaint, the History of Present Illness and the Past Medical History. Relevant here
is the History of Present Illness. This refers to the events and activities of the patient
which transpired prior to the consultation, from the onset of symptoms to the time of
consultation.
PROSECUTOR AYN SARSABA: Now, you mentioned about an informant. Who
was the informant of the patient in this case, Doctor? Was it Miss Merin?
ATTY. TAPIRE: Objection, Your Honor, the question is leading!
PROSECUTOR AYN SARSABA: Who was the informant of the patient in this
case?
DR. JUAN PAOLO GASCON: It was Miss Iris Merin.
PROSECUTOR AYN SARSABA: Would you please tell the Court what it was
exactly that Miss Merin told you?
DR. JUAN PAOLO GASCON: The informant told me that during their coffee break
on the day of the incident, the food intake of the patient consisted of tuna sandwich,
fresh green salad, green tea Frappuccino, and during the party, she drank coke zero.
PROSECUTOR AYN SARSABA: Now, my question to you is: Is it possible Doctor
that a grape fruit juice can be a source of the cyanide poison?
ATTY. TAPIRE: Objection, the question is leading.
Court: Sustained.
DR. JUAN PAOLO GASCON: Actually, during the confinement of the patient in
the hospital for one week, said patient mentioned to me that she also drank grape fruit
juice. It is possible that the grape fruit juice could be the source of cyanide
considering that she ingested the same 3 hours before the onset of symptoms.
PROSECUTOR AYN SARSABA: What is the minimum lethal dose of cyanide?
DR. JUAN PAOLO GASCON: Fatal dose is the smallest dose known to cause
death: not the smallest amount which will certainly cause death. Several scientific
studies have shown that the toxic threshold dose is 50 to 100mg of cyanide in the
human body.
PROSECUTOR AYN SARSABA: In your opinion, was the dose taken by the victim
necessarily fatal?
DR. JUAN PAOLO GASCON: An analysis of the patients blood would tell us the
amount or level of cyanide in the blood. The patients blood was found to have 1.5
mg/dL cyanide content. Based from this definitive finding, I can extrapolate that the
amount ingested by the patient is lethal or fatal.
PROSECUTOR AYN SARSABA: Is that all, Doctor?
DR. JUAN PAOLO GASCON: As previously stated, the symptoms of the patient
would eventually lead to cardio-pulmonary arrest (death). If no prompt intervention
was done, the patient would have died.
PROSECUTOR AYN SARSABA: What are you trying to tell us Doctor?
DR. JUAN PAOLO GASCON: The severity of the symptoms may serve as an
indication of how lethal the dose of cyanide is. Or that the effect of poisons in the
body is usually proportional to the dose taken. The bigger the dose, the more severe
the symptoms will be.
PROSECUTOR AYN SARSABA: Doctor, do you have any other field of expertise?
DR. JUAN PAOLO GASCON: Yes. I am also an expert chemist and toxicologist. I
specialize in Forensic Medicine and Toxicology specifically Poisoning and Drug
Overdose.
PROSECUTOR AYN SARSABA: I will show you a document, previously marked
as Exhibit E. This is the Toxicology Report from the NBI on the results of their
chemical analyses of the sample taken from the grape fruit juice in the pitcher and of
the sample taken from the rodenticide or rat killer, Rat-A-Rest, found in the apartment
of the complainant and accused.
PROSECUTOR AYN SARSABA: As an expert, can you please interpret to us the
findings in this report?
DR. JUAN PAOLO GASCON: This report reveals that the sample taken from the
grape fruit juice has been contaminated with rodenticide. It also shows that
rodenticide has 50% cyanide concentration. It also illustrates that the grape fruit juice
is hence contaminated with cyanide.
PROSECUTOR AYN SARSABA: Doctor, have you formed an opinion?
DR. JUAN PAOLO GASCON: It seems that the rodenticide has been intentionally
mixed into the grape fruit juice.
PROSECUTOR AYN SARSABA: No more questions, Your Honor.
COURT: Cross?
ATTY. TAPIRE: Yes, Your Honor.
CROSS EXAMINATION OF DR. JUAN PAOLO GASCON (EXPERT
WITNESS) BY ATTY. PAULETTE TAPIRE (DEFENSE COUNSEL)
ATTY. PAULETTE TAPIRE: Doctor, you have testified that you also specialize in
Toxicology specifically Poisoning and Drug Overdose, hence, you are an expert in
that field, am I right?
ATTY. PAULETTE TAPIRE: Doctor, when does ingestion of the cyanide poison
cause the onset of symptoms of cyanide poisoning?
DR. JUAN PAOLO GASCON: Patients who ingest potentially fatal amounts may
not develop life-threatening symptomatology for up to 1 to 2 hours following
exposure.
ATTY. PAULETTE TAPIRE: Symptoms such as?
DR. JUAN PAOLO GASCON: In patients who do not experience sudden collapse,
the initial signs and symptoms can resemble those of anxiety or hyperventilation
syndrome. Early signs include headache. Late signs of poisoning are nausea,
vomiting, loss of consciousness, and a variety of cardiac effects.
ATTY. PAULETTE TAPIRE: The patient-complainant also testified that she drank
two glasses of the alleged source of the poison the grape fruit juice at around 2:45 pm
and the onset of the symptoms of cyanide poisoning was about 6:00 pm. Thus, 3
hours had lapsed from the ingestion of the alleged source (grape fruit juice) before the
symptoms developed, am I right? A: Yes. Q: But you also said that symptoms of
cyanide poisoning are expected to develop 1 to 2 hours following ingestion?
ATTY. PAULETTE TAPIRE: If thats the case, dont you think there is an
inconsistency of the duration of ingestion and onset of symptoms between the patients
actual case and the established scientific findings of cyanide poisoning? With this,
does it not mean that the condition of the patient can not be attributed to cyanide
poisoning but to some other cause?
DR. JUAN PAOLO GASCON: Yes. That is possible.
ATTY. PAULETTE TAPIRE: Are you sure?

DR. JUAN PAOLO GASCON: I can say that it is possible that the patients
condition was not due to cyanide poisoning.
ATTY. PAULETTE TAPIRE: Doctor, about the source of the poison, you only said
possible sources, right?
ATTY. PAULETTE TAPIRE: In your opinion, is said fact relevant to the

determination of the cause of the symptoms?
DR. JUAN PAOLO GASCON: Yes. History of any previous suicidal attempts,
history of the patients mental condition and history of business, marital and social
failures are taken into consideration in cases of poisoning.
ATTY. PAULETTE TAPIRE: Is it safe to conclude then that it is possible that the
poisoning is attributable to suicide?
ATTY. PAULETTE TAPIRE: By possible, you mean?
DR. JUAN PAOLO GASCON: Yes, Your Honor.
A: Probable or potential source of the poison, Maam.
ATTY. PAULETTE TAPIRE: No further questions, Your Honor.
ATTY. PAULETTE TAPIRE: That the grape fruit juice is just one possible source
of the cyanide poison?
COURT: Re-direct?

ATTY. PAULETTE TAPIRE: And that there are other possible sources of the
cyanide as well?
ATTY. PAULETTE TAPIRE: So, is it safe to conclude, Doctor, that the cyanide
poison may have come from another source considering that for that day, the patients
food intake comprised of different food and beverages?
DR. JUAN PAOLO GASCON: Yes, that is possible.
ATTY. PAULETTE TAPIRE: Are you aware of the history of said patient, that she
had at one time in the past, attempted to end her life due to depression?
ATTY. PAULETTE TAPIRE: That she has a history of one previous suicidal
attempt one year from the date of the incident?
PROSECUTOR SARSABA: Yes, Your Honor

RE-DIRECT EXAMINATION OF DR. JUAN PAOLO GASCON(EXPERT
WITNESS) BY PROSECUTOR SARSABA (PROSECUTION COUNSEL)
PROSECUTOR SARSABA: Doctor, is it possible that the onset of symptoms for
cyanide poisoning varies for each person? Is it possible that said symptoms may
appear beyond the normal 1-2 hour duration?
DR. JUAN PAOLO GASCON: That is possible.
PROSECUTOR SARSABA: Will you explain to us how that is possible?
DR. JUAN PAOLO GASCON: Some persons possess different levels of sensitivity
to certain substances. The body may acquire tolerance to some substances. Another
would be: The body has a natural defense against cyanide exposure in the form of an
endogenous enzyme, namely, rhodamine. This enzyme catalyzes cyanide complexing
with sulfur, forming the much less toxic ion thiocyanate. The availability of sulfur
constitutes the rate limiting factor in natural cyanide detoxification. In the absence of
exogenous source of sulfur, rhodamine activity is too slow to prevent serious toxicity
or death.
PROSECUTOR SARSABA: Could you explain to the Court what you mean by that
Doctor?
Exhibit A-3 is the stipulation regarding the pest control measures to prove that the
lessor undertakes to conduct the quarterly pest control measures.
DR. JUAN PAOLO GASCON: Even though the normal duration is 1 to 2 hours,
there are some cases in which the signs and symptoms of cyanide poisoning in a
patient may be delayed and appear beyond the normal duration. In the case of the
patient Miss Manarang, there was a one-hour delay of appearance of symptoms
because as confirmed in her lab tests, her body produces abnormal amounts of sulfur
and as Ive mentioned earlier, when there is more sulfur in the body, the cyanide
detoxification in the body is hastened, thus, the serious toxic effects of cyanide will
be diminished. Lastly, the food intake of the patient may possibly contribute to such
effect.
Exhibit B is the pitcher from which a sample was taken and subjected to chemical
analysis for the purpose of proving the fact that the source of poison was the
grapefruit juice prepared by the accused contained in the pitcher.
PROSECUTOR SARSABA: No further questions, Your Honor.

COURT: Re-cross?
Exhibit D is the Medico Legal Report issued by Dr. Juan Paolo Gascon to prove the
following:
ATTY. TAPIRE: No re-cross, Your Honor.
(i) that the effective cause of the complainants condition is chemical poisoning;
COURT: Mr. Witness, you may step down. Formal Offer of Evidence by the
Prosecution
(ii) that the dose taken by the complainant is necessarily fatal;
PROSECUTOR SARSABA: Your Honor, we are now resting the case for the
prosecution.
COURT: How do you intend to submit your formal offer?
PROSECUTOR SARSABA: We can now offer our evidence, Your Honor.
COURT: Proceed
PROSECUTOR SARSABA: Exhibit A is the Contract of Lease being offered to
prove that there is a stipulation on the quarterly conduct of pest control measures by
the lessor. Exhibit A-1 and A-2 are the signatures of Catherine Jane Manarang as
lessee and Rhandell Matuloy as lessor to prove that these two persons were the
contracting parties to the lease agreement.
Exhibit C consists of text messages to prove that the accused nurtured feelings for the
complainants boyfriend.
Exhibit C-1 consists of printed copies of the text messages to corroborate to the fact
that the accused had been sending several text messages to the complainants
boyfriend to manifest her obsession.
and (iii) that the possible source of cyanide poison is the grapefruit juice prepared by
the accused.
Exhibit D-1 is the signature of Dr. Juan Paolo Gascon to be a part of his testimony
that he was the attending physician of the complainant.
Exhibit E is the Toxicology Report of the National Bureau of Investigation to prove
the chemical analysis of the sample taken from the pitcher for qualitative and
quantitative determination of the poison. Exhibit F is the Box of Rat Killer to prove
the source of the poison which was bought by the accused.
COURT: Any comment?
ATTY. OCAMPO: As to Exhibits A, A-1, A-2 and A-3 we admit the existence and
authenticity, Your Honor. As to Exhibit B, we admit its existence but not its purpose.
As to Exhibits C and C-1, we can only admit as to the existence of the text messages
but not its authenticity. As to Exhibit D and D-1, we admit the existence and
authenticity, Your Honor. As to Exhibit E, we admit its authenticity and genuineness.

As to Exhibit F, we admit its existence but not its purpose.
ATTY. HELEN PAULETTE TAPIRE: From what university or college did you
graduate and when?
COURT: Acting on the formal offer of exhibits of the prosecutor and comments
thereon by the defense counsel, the Court resolves to admit all the exhibits offered by
the defense counsel specified in the offer.
DR.LEIRA TARUC: I graduated from the University of Santo Tomas in the year
1994.
DEFENSE DIRECT EXAMINATION OF DR.LEIRA TARUC (EXPERT

WITNESS) BY ATTY. HELEN PAULETTE TAPIRE (DEFENSE COUNSEL)
ATTY. HELEN PAULETTE TAPIRE: For the defense, we are ready to present our
first witness, Your Honor.
ATTY. HELEN PAULETTE TAPIRE: Did you graduate with honors?

DR.LEIRA TARUC: Yes, Latin Honors Your Honor.
ATTY. HELEN PAULETTE TAPIRE: Do you have any post-graduate degree?
COURT: Proceed.
DR.LEIRA TARUC: Yes, Your Honor. I finished my Master of Psychiatry degree at

the University of Melbourne in 1998.
truth in this case?
ATTY. HELEN PAULETTE TAPIRE: Since when have you been practicing as a
psychiatrist?
DR.LEIRA TARUC: Yes Maam.
DR.LEIRA TARUC: For almost 10 years, Your Honor.
ATTY. HELEN PAULETTE TAPIRE: What is the nature of your work as a

psychiatrist?
DR.LEIRA TARUC: I am Dr. Leira Leonor Taruc, 35 years old, single, a licensed
psychiatrist at the Psychiatry Department, Medical Center Manila, and a resident of
123 Krusada St. Quaipo, Manila.
DR.LEIRA TARUC: As a psychiatrist I deal with the diagnosis, treatment and

prevention of mental and emotional illness and behavioral disorders of patients.
ATTY. HELEN PAULETTE TAPIRE: Your Honor, the witness is presented to

testify on the medical records of the complainant who underwent several counseling
sessions under her supervision and to prove the mental and emotional instability of
the complainant. May we proceed, Your Honor?
COURT: Proceed.
ATTY. HELEN PAULETTE TAPIRE: How do you treat your patients?

DR.LEIRA TARUC: I listen and talk to patients about their mental, emotional or
behavioral problems and assess the status of these disorders. I also prescribe
medications, cognitive therapy, behavioral therapy or psychological counseling
depending on the patients needs.
ATTY. HELEN PAULETTE TAPIRE: When were you admitted to the practice of
medicine?
ATTY. HELEN PAULETTE TAPIRE: Do you know the complainant in this case?
DR.LEIRA TARUC: In 1995, Your Honor.
ATTY. HELEN PAULETTE TAPIRE: Why do you know her?
DR.LEIRA TARUC: Yes, Your Honor.
DR.LEIRA TARUC: She was my patient at the Psychiatry Department of Medical

Center Manila.
ATTY. HELEN PAULETTE TAPIRE: When was this?
DR.LEIRA TARUC: August 16, 2006.
ATTY. HELEN PAULETTE TAPIRE: For what reason did she come to your
clinic?
DR.LEIRA TARUC: She consulted me about her condition.
ATTY. HELEN PAULETTE TAPIRE: Was the consultation out of her own
volition?
DR.LEIRA TARUC: No. She was advised by her friend.
ATTY. HELEN PAULETTE TAPIRE: Doctor, what procedures or tests did you
conduct on the complainant during the consultation?
DR.LEIRA TARUC: I conducted physical examinations. I asked her to tell
something about her, her work, her family, and other personal relationships. I just
listened to whatever she said. While she was talking, I observed her demeanor, the
way she spoke, and her gestures.
ATTY. HELEN PAULETTE TAPIRE: What did you notice about the complainant
while she was talking to you?
DR.LEIRA TARUC: At first, the patient was apparently normal. But when she began
talking about her family, particularly her parents, she began to sob, and then she cried.
Her hands were trembling. She blamed herself for the death of her parents.
ATTY. HELEN PAULETTE TAPIRE: What matters were revealed to you by the
complainant in the course of the consultation?
DR.LEIRA TARUC: The physical examinations revealed sleeping apnea, insomnia,
hypertension, and migraines.
ATTY. HELEN PAULETTE TAPIRE: As to her emotional condition?

DR.LEIRA TARUC: The patient is suffering from major depression, without
psychotic features.
ATTY. HELEN PAULETTE TAPIRE: Did you talk to anyone else regarding the
patients emotional condition?
ATTY. HELEN PAULETTE TAPIRE: Who else did you talk to about her
emotional condition?
DR.LEIRA TARUC: I spoke to her friend, the one who advised the patient to seek
help. This was part of the analysis of the patients condition.
ATTY. HELEN PAULETTE TAPIRE: Any other tests that you conducted on the
patient?
DR.LEIRA TARUC: No more, Your Honor.
ATTY. HELEN PAULETTE TAPIRE: Doctor, from the examinations and
observations, what did you conclude about the complainants condition?
DR.LEIRA TARUC: The patient from suffered from single episode depression.
ATTY. HELEN PAULETTE TAPIRE: Will you explain to this Court what that
condition meant?
DR.LEIRA TARUC: Single episode depression or SED is a type of major depression
that occurs once, as a result of a single psychological trauma. In the case of the
patient, based on our conversations, the only traumatic event which caused the
depression was the terrible accident and death of her parents.
ATTY. HELEN PAULETTE TAPIRE: What made you conclude that the patient
was suffering from this condition?
DR.LEIRA TARUC: The symptoms of SED, which include insomnia, loss of

appetite, which may, or may not lead to weight loss, mood swings and hypnotic
spells, matched with the results of the patients physical examination.
ATTY. HELEN PAULETTE TAPIRE: How did you treat the patient?
DR.LEIRA TARUC: September 16, 2006, Your Honor.

ATTY. HELEN PAULETTE TAPIRE: The medical findings that you had on the
complainant, were these reduced into writing?
DR.LEIRA TARUC: The patient was admitted to the hospital as inpatient.
DR.LEIRA TARUC: Yes, Your Honor, I have made a psychiatric assessment on the
medical findings.
ATTY. HELEN PAULETTE TAPIRE: How long did she stay at the hospital?
ATTY. HELEN PAULETTE TAPIRE: Did you personally prepare the said writing?
DR.LEIRA TARUC: One month, Your Honor.
ATTY. HELEN PAULETTE TAPIRE: And what methods or procedures did you
use to treat the patient?
ATTY. HELEN PAULETTE TAPIRE: Does this document have any relation to the
report that you have prepared? (Showing the psychiatric assessment)
DR.LEIRA TARUC: I conducted supportive counseling, Your Honor.
DR.LEIRA TARUC: That is the report that I have prepared, Your Honor.
ATTY. HELEN PAULETTE TAPIRE: Will you tell this Honorable Court what
supportive counseling meant?
ATTY. HELEN PAULETTE TAPIRE For the record, the witness has identified this
document previously marked as Exhibit 2 as the psychiatric assessment record of
Catherine Jane Manarang.
DR.LEIRA TARUC: Supportive counseling helps ease the pain of depression and
addresses the feeling of hopelessness that accompanies the depression. In the case of
the patient, I talk to her about what happened to her during the past week. If the
patient mentioned a negative event, I ask her what she felt, why she felt that way and
how she should have viewed the negative situation.
ATTY. HELEN PAULETTE TAPIRE: In the last page of this document, there
appears a signature. Whose signature is this, Miss Witness?
DR.LEIRA TARUC: That is my signature, Your Honor.
ATTY. HELEN PAULETTE TAPIRE: And the counseling sessions were at what
intervals?
ATTY. HELEN PAULETTE TAPIRE: I respectfully request, Your Honor, that the
signature appearing in this document be marked as Exhibit 2-A.
DR.LEIRA TARUC: Once a week, Your Honor.
COURT: Mark it.
ATTY. HELEN PAULETTE TAPIRE: Did you prescribe any medication to the
patient?
ATTY. HELEN PAULETTE TAPIRE: Doctor, who ordered the discharge of the
complainant?
DR.LEIRA TARUC: Yes, I prescribed anti-depressant pills.
DR.LEIRA TARUC: I ordered the discharge, Your Honor, upon request of the
complainant?
ATTY. HELEN PAULETTE TAPIRE: When did you discharge the complainant/
patient?
ATTY. HELEN PAULETTE TAPIRE: Were there any conditions upon the
discharge of the complainant?
DR.LEIRA TARUC: In my discharge summary, I stated that although the patient is

being discharged, she is to continue treatment as an outpatient.
ATTY. HELEN PAULETTE TAPIRE: Did the patient comply with the condition?
DR.LEIRA TARUC: That is possible, Your Honor.

ATTY. HELEN PAULETTE TAPIRE: No further questions, Your Honor.
COURT: Cross?
DR.LEIRA TARUC: No, Your Honor. She did not return to the hospital after the
discharge.
PROSECUTOR SARSABA: Yes, Your Honor.
ATTY. HELEN PAULETTE TAPIRE: Doctor, when the complainant was

discharged, what was her condition?
CROSS EXAMINATION OF DR. LEIRA TARUC (EXPERT WITNESS) BY

PROSECUTOR AYN SARSABA (PROSECUTION COUNSEL)
DR.LEIRA TARUC: There was an improvement in her condition in general,

although she is not completely stable yet.
PROSECUTOR AYN SARSABA: Doctor, you testified that you treated the
complainant for single episode depression. Is that true?
ATTY. HELEN PAULETTE TAPIRE: What do you mean she is not completely
stable yet?
DR.LEIRA TARUC: While she manifested improvement, there is a possibility of

relapse.
PROSECUTOR AYN SARSABA: When you discharged the complainant, what was
her condition?
DR.LEIRA TARUC: She was emotionally stable.
ATTY. HELEN PAULETTE TAPIRE: Do you mean to say, Doctor, that the
patients condition may recur?
PROSECUTOR AYN SARSABA: What made you conclude that the patient was
emotionally stable?
DR.LEIRA TARUC: If unguarded, Your Honor.
DR.LEIRA TARUC: During our last counseling session, there were no longer signs
of the SED. She no longer showed signs of mood swings. She no longer cried when I
asked her about the death of her parents. She said she would not blame herself
anymore.
ATTY. HELEN PAULETTE TAPIRE: Unguarded

DR.LEIRA TARUC: If the patient does not follow the treatment plan, the possibility
of relapse is high.
ATTY. HELEN PAULETTE TAPIRE: Do you mean to say, Doctor, that, in the
case of the complainant, there is a possibility of a relapse, considering she did not
return to you for further treatment?
PROSECUTOR AYN SARSABA: You also testified that your relationship with the
complainant lasted for one month. Will you tell this Honorable Court why it lasted
only for such period?
DR.LEIRA TARUC: The patient responded well during our counseling sessions. The
anti-depressant pills which I have prescribed also worked positively on her.
ATTY. HELEN PAULETTE TAPIRE: And should there be a relapse, would

another suicide be also a possibility?
PROSECUTOR AYN SARSABA: The anti-depressant pills that you prescribed; do

they have any side effects?
DR.LEIRA TARUC: I asked the patient what she felt after taking the medication.
She said she felt drowsy, which is a normal side effect of anti-depressants.
PROSECUTOR AYN SARSABA: Are there any other side effects?
COURT: Sustained.
PROSECUTOR AYN SARSABA: No further questions, Your Honor.
COURT: Re-direct?
DR.LEIRA TARUC: Other anti-depressants make a patient restless and anxious. But
the effects really vary from one person to another. In the case of the complainant, the
only effect was drowsiness.
ATTY. TAPIRE: No, Your Honor. We will call on our last witness.
PROSECUTOR AYN SARSABA: You testified that a relapse is possible if the

patient does not continue treatment after discharge, is that true?
DIRECT EXAMINATION OF KATE NUNEZ (OFFICEMATE

COMPLAINANT (DEFENSE WITNESS) BY ATTY. ANALITA OCAMPO
ATTY. ANALITA OCAMPO : May I call on our next witness, Miss Kate Nunez.
PROSECUTOR AYN SARSABA: How high are the chances of a relapse?

DR.LEIRA TARUC: It depends, Your Honor.
truth in this case?
PROSECUTOR AYN SARSABA: Depends on what?
KATE NUNEZ: Yes Maam.
DR.LEIRA TARUC: If the patient is under several medications and they are not
followed, a relapse is highly possible. And if the patient does not submit to further
counseling sessions when required, a relapse is also possible.
PROSECUTOR AYN SARSABA: Was the complainant under medication when she
was discharged?
ATTY. ANALITA OCAMPO
DR.LEIRA TARUC: Yes, but only for anti-depressant, Your Honor.
The witness is being presented to testify on the character and suicidal tendencies of
the complainant. May we proceed, Your Honor?
PROSECUTOR AYN SARSABA: So in your opinion, is the possibility of a relapse

high or low?
COURT: Proceed.
DR.LEIRA TARUC: I cannot tell, Your Honor.

PROSECUTOR AYN SARSABA: Would that also mean that, in the case of the
complainant, such relapse may not happen?
ATTY. TAPIRE: Objection, Your Honor, the question is leading.
COURT: Miss Witness, You may step down. Call your last witness.
OF
KATE NUNEZ: I am Kate Nunez, 32 years old, married, an officemate of the

complainant and a resident of 345, Paco, Manila.
ATTY. ANALITA OCAMPO : Do you know the complainant?

KATE NUNEZ: Yes, Your Honor.
ATTY. ANALITA OCAMPO : Why do you know her?
KATE NUNEZ: I work with her at the accounting department at Nestle Philippines.
ATTY. ANALITA OCAMPO : How long have you been officemates?
A: I said, Come on, you can tell me your problems.
KATE NUNEZ: About two years.
ATTY. ANALITA OCAMPO : Did this kind of incident happen again?
ATTY. ANALITA OCAMPO : How would you describe her as an officemate?
KATE NUNEZ: Yes. Two days after, the same incident happened in the comfort
room.
KATE NUNEZ: She is a quiet person, a loner.

ATTY. ANALITA OCAMPO : In the two years that youve known the complainant,
was there any untoward incident which involved her?
KATE NUNEZ: None sir.
ATTY. ANALITA OCAMPO : Was there any time that you noticed something
different about the complainant?
KATE NUNEZ: Yes.
ATTY. ANALITA OCAMPO : What did you do during that second incident?
KATE NUNEZ: None. I did not ask her anymore because I know she wouldnt tell
me anyway.
ATTY. ANALITA OCAMPO : Do you remember what transpired afterwards?
KATE NUNEZ: After about three days, I learned of the complainants attempt to
commit suicide.
ATTY. ANALITA OCAMPO : What was that?
ATTY. ANALITA OCAMPO : Miss Witness, on June 22, 2006, did you receive an
e-mail from the complainant?
KATE NUNEZ: I saw her one time at the comfort room, she was crying while
staring at the mirror.
ATTY. ANALITA OCAMPO : What did you do when you saw her crying?
KATE NUNEZ: I asked her if something wrong happened.
ATTY. ANALITA OCAMPO : What was her answer?
KATE NUNEZ: She said, I want to die
ATTY. ANALITA OCAMPO : Who was the sender of that e-mail?

KATE NUNEZ It was Catherine, Your Honor.
ATTY. ANALITA OCAMPO : How do you know?
KATE NUNEZ: Because she used her signature, Your Honor.
ATTY. ANALITA OCAMPO : What did you tell her after she said those words?
ATTY. ANALITA OCAMPO : Miss Witness, please examine this writing, and
please tell the Court if you recognized it?
KATE NUNEZ: I asked her again what happened
KATE NUNEZ: That is the e-mail sent by the complainant, Your Honor.
ATTY. ANALITA OCAMPO : And what was her answer?
ATTY. ANALITA OCAMPO : For the record, the witness has identified this
document previously marked as Exhibit A as the printed copy of the e-mail sent by
the complainant.
KATE NUNEZ: She did not say anything, she just stared at me.
ATTY. ANALITA OCAMPO : What was your reaction?
ATTY. ANALITA OCAMPO : Can you tell the Court what the e-mail contained?
KATE NUNEZ: It says: Dear Kate, my parents didnt deserve to die that way. I
am so stupid, I should have died with them. I want to die now
ATTY. ANALITA OCAMPO : How sure are you that this is the same e-mail which
you received from the complainant?
KATE NUNEZ: Because her signature appears at the bottom of the e-mail, Your
Honor.
ATTY. ANALITA OCAMPO : This signature appearing here, is this the signature of
the complainant?
ATTY. OCAMPO: Your Honor, it is respectfully requested that the signature
appearing in this Exhibit 3 be marked as Exhibit 3-A.
IRIS VICTORIA MERIN Iris Victoria Uy Merin, 28 years of age, single, food
toxicologist at the Research and Development Division Nestle Philippines, and a
resident of Unit 143 Astral Apartment Padre Faura St. Ermita, Manila. COURT: Your
witness.
ATTY. HELEN PAULETTE TAPIRE: Your Honor, the testimony of the witness is
being offered to controvert the material allegations of the information against Iris
Victoria Merin and to testify that due to the complainants mental and emotional state,
her perspective of the situation cannot be relied upon. May we proceed, Your Honor?
COURT: Proceed.
ATTY. HELEN PAULETTE TAPIRE: Miss Witness, are you the same Iris Victoria
Merin who is the accused in this case?
IRIS VICTORIA MERIN: Yes, Your Honor.
ATTY. OCAMPO: No further questions.
ATTY. HELEN PAULETTE TAPIRE: Do you know the complainant?
COURT: Cross?
PROSECUTOR SARSABA: No cross- examination for the witness, your honor.
ATTY. HELEN PAULETTE TAPIRE: Do you know her personally?
DIRECT EXAMINATION OF IRIS VICTORIA MERIN (ACCUSED) BY

ATTY. HELEN PAULETTE TAPIRE (DEFENSE COUNSEL)
ATTY. HELEN PAULETTE TAPIRE: For the defense, we are ready to present the
accused, Your Honor.
COURT: Proceed.
truth in this case?
IRIS VICTORIA MERIN Yes Maam.
ATTY. HELEN PAULETTE TAPIRE: How are you related to her?

IRIS VICTORIA MERIN: She is a childhood friend. We work in the same company
and we live in the same apartment.
ATTY. HELEN PAULETTE TAPIRE: Iris Merin, please tell this Honorable Court,
where were you on October 17, 2007 at around 6pm?
IRIS VICTORIA MERIN: I was at the engagement party of Catherine and Richard.
ATTY. HELEN PAULETTE TAPIRE: Can you recall what happened during that
engagement party?
IRIS VICTORIA MERIN: I was chatting with Catherine while having a drink. We
were in the kitchen then. Afterwards, I saw her holding her abdomen and vomiting.
ATTY. HELEN PAULETTE TAPIRE: What were you drinking that time?
IRIS VICTORIA MERIN: I was drinking margarita, she was drinking Coke zero.
ATTY. HELEN PAULETTE TAPIRE: Then what happened?
IRIS VICTORIA MERIN: She dropped to the ground. She was so pale and sweaty.
She lost her consciousness. Ritchie called for an ambulance and then we brought her
to the nearby hospital.
IRIS VICTORIA MERIN: I left the house 6:30 am.

ATTY. HELEN PAULETTE TAPIRE So could you positively say that you had no
idea about what transpired on that day, October 17, 2007, before the incident at the
engagement party happened?
PROSECUTOR PRESTOZA: Objection, Your Honor! The question is leading.
COURT: Sustained.
ATTY. HELEN PAULETTE TAPIRE: When you left the house, what was
Catherine doing?
ATTY. HELEN PAULETTE TAPIRE: How long did you stay at the hospital?
IRIS VICTORIA MERIN: She was still sleeping, Your Honor.
IRIS VICTORIA MERIN: I stayed there overnight.
ATTY. HELEN PAULETTE TAPIRE: Miss Witness, were you aware that the
complainant suffered from a major depression?
ATTY. HELEN PAULETTE TAPIRE: Before the incident happened, where were
you?
IRIS VICTORIA MERIN: I was at the Starbucks with Catherine.
ATTY. HELEN PAULETTE TAPIRE: At around what time was that?

ATTY. HELEN PAULETTE TAPIRE: Would you know the reason why she
suffered from that depression?
IRIS VICTORIA MERIN: It was around 3pm. It was my coffee break then.
IRIS VICTORIA MERIN: Because she couldnt accept the untimely death of her
parents. She blamed herself for their death.
ATTY. HELEN PAULETTE TAPIRE: Did Catherine go to work that day?
ATTY. HELEN PAULETTE TAPIRE: When did her parents die?
IRIS VICTORIA MERIN: No, Your Honor.
IRIS VICTORIA MERIN: Around May of 2006.
ATTY. HELEN PAULETTE TAPIRE: Would you know why?
ATTY. HELEN PAULETTE TAPIRE: After the death of the complainants parents,
what happened to the complainant?
IRIS VICTORIA MERIN: She told me she would take a leave because she needed
to prepare for their engagement party.
IRIS VICTORIA MERIN: Yes.
IRIS VICTORIA MERIN: She became insomniac. There were nights that she
couldnt sleep. She also drank liquor more often. She began to lose weight. There were
also mood swings, particularly in the afternoon. There were times that she would just
cry. Sometimes she just keeps quiet and not talk to me.
ATTY. HELEN PAULETTE TAPIRE: What time did you leave the house?
ATTY. HELEN PAULETTE TAPIRE: Did the complainant remain that way?
ATTY. HELEN PAULETTE TAPIRE: Did you go to work that day?

ATTY. HELEN PAULETTE TAPIRE: For how long did she remain that way?
IRIS VICTORIA MERIN: I think around two months, before she attempted to end
her life.
ATTY. HELEN PAULETTE TAPIRE: When did she attempt to commit suicide?
IRIS VICTORIA MERIN: Hmm, sometimes she suddenly kept quiet. There were
times I caught her crying silently.
ATTY. HELEN PAULETTE TAPIRE: No further questions, Your Honor. COURT:
Cross?
PROSECUTOR PRESTOZA: Yes, Your Honor.
IRIS VICTORIA MERIN: Around July or August 2006, Your Honor.

ATTY. HELEN PAULETTE TAPIRE: After she committed suicide, what
happened?
IRIS VICTORIA MERIN: She sought the help of a psychiatrist.
ATTY. HELEN PAULETTE TAPIRE: Did you advise her to seek medical help?
CROSS EXAMINATION OF IRIS VICTORIA MERIN (ACCUSED) BY

PROSECUTOR ANTHONY PRESTOZA (PROSECUTION COUNSEL)
PROSECUTOR ANTHONY PRESTOZA: In the direct examination, you told this
Honorable Court that you work as a food toxicologist, how long have you been
practicing this profession?
IRIS VICTORIA MERIN: No, Your Honor, because I was afraid shed say I think
shes crazy.
IRIS VICTORIA MERIN: 7 years.
ATTY. HELEN PAULETTE TAPIRE: Did you do anything to help her?

IRIS VICTORIA MERIN: I specialize in chemical analysis of food composition and

toxicity of food contents.
ATTY. HELEN PAULETTE TAPIRE: What did you do to help her in her
condition?
PROSECUTOR ANTHONY PRESTOZA: So, you have knowledge of different

kinds of chemicals and food substances?
IRIS VICTORIA MERIN: I was always talking to her, asking her how she feels, I
kept telling her not to be depressed anymore. I also told her to stop drinking.
IRIS VICTORIA MERIN: Yes.
ATTY. HELEN PAULETTE TAPIRE: After she sought the help of a psychiatrist,
what happened?
IRIS VICTORIA MERIN: Catherine recovered from the depression. She was
sleeping well and was no longer drinking often.
ATTY. HELEN PAULETTE TAPIRE: No more signs of the depression were
present?
PROSECUTOR ANTHONY PRESTOZA: What is your specialization?
PROSECUTOR ANTHONY PRESTOZA: Are you familiar with rodenticide?
PROSECUTOR ANTHONY PRESTOZA: Is it poisonous?

PROSECUTOR ANTHONY PRESTOZA: Do you think it can kill a person?
IRIS VICTORIA MERIN: Depending on the amount, Your Honor.
PROSECUTOR ANTHONY PRESTOZA: Do you use rodenticide?
IRIS VICTORIA MERIN: None
IRIS VICTORIA MERIN: Yes, we use them for killing house rats.
PROSECUTOR ANTHONY PRESTOZA: Does this mean that either only you or
Catherine prepares the food and drinks that may be found in the apartment.
PROSECUTOR ANTHONY PRESTOZA: Do you have a rodenticide at home?

PROSECUTOR ANTHONY PRESTOZA: Do you recognize this box of rat killer,
previously marked as Exhibit F?
PROSECUTOR ANTHONY PRESTOZA: Was this the package that contained the
rat killer?
IRIS VICTORIA MERIN: Yes. Except those which are ready to eat or drink. And
sometimes if a close female relative from the province decides to stay for a while in
the city, we allow her to stay in the apartment.
PROSECUTOR ANTHONY PRESTOZA: The night before Catherine was
poisoned, were there any other person staying with you in the apartment?
IRIS VICTORIA MERIN: None sir.
PROSECUTOR ANTHONY PRESTOZA: So during that time, all the drinks and
food inside the apartment were either prepared by you or Catherine?
PROSECUTOR ANTHONY PRESTOZA: Were you the one who bought this?
IRIS VICTORIA MERIN: Most probably, Your Honor.
IRIS VICTORIA MERIN: No. It was Catherine who bought it because she intends
to clean the apartment and to eliminate the rats at home.
PROSECUTOR ANTHONY PRESTOZA: Are you aware of the findings of the

doctor who attended Catherine that she was poisoned around 6 hours earlier before
she was brought to the Hospital?
PROSECUTOR ANTHONY PRESTOZA: Miss Witness, were you aware of the

provision in the lease contract which said that it is the responsibility of the lessor to
conduct quarterly pest control measures?
IRIS VICTORIA MERIN: Yes, Your Honor. In fact, I was surprised why Catherine
bought rodenticide, well in fact our lease agreement provides that we should report
any complaints we have to the lessor.
PROSECUTOR ANTHONY PRESTOZA: How long have you been staying with
the complainant in the same apartment?
IRIS VICTORIA MERIN: About 8 years now, Your Honor.
PROSECUTOR ANTHONY PRESTOZA: Do you have any other companion in
the apartment where you and Catherine stay?
PROSECUTOR ANTHONY PRESTOZA: Where were you during that time?

IRIS VICTORIA MERIN: I was in the office. I have work.
PROSECUTOR ANTHONY PRESTOZA: On the day of the incident, what time
did you wake up?
IRIS VICTORIA MERIN: The usual. 5:30 AM.
PROSECUTOR ANTHONY PRESTOZA: Did you wake up earlier than
Catherine?
IRIS VICTORIA MERIN: Yes, Your Honor
PROSECUTOR ANTHONY PRESTOZA: During that time, did you notice any
grapefruit juice in the ref?
IRIS VICTORIA MERIN: Yes. We always have some stock of juice.

PROSECUTOR ANTHONY PRESTOZA: Did you nurture any affection towards
him?
PROSECUTOR ANTHONY PRESTOZA: You testified that you and the

complainant were childhood friends. Were you not concerned during the time that she
suffered from depression?
PROSECUTOR ANTHONY PRESTOZA Objection, Your Honor, counsel is

speculating. (Pag overruled, ANSWER: I was concerned about her, but knowing her,
she would not tell me how she feels because she liked keeping things to herself) (Pag
sustained, reform the question to: WHAT DID YOU DO TO HELP THE
COMPLAINANT DURING THE TIME SHE WAS SUFFERING FROM
DEPRESSION? Answer: I was always talking to her, asking her how she feels, if she
was okay or not.)
PROSECUTOR ANTHONY PRESTOZA: Miss Witness, do you know the fianc

of the complainant?
PROSECUTOR ANTHONY PRESTOZA: How did you come to know him?
IRIS VICTORIA MERIN: He is the head security officer of the company where I
and Catherine work.
PROSECUTOR ANTHONY PRESTOZA: Are you not jealous of your best friend?
PROSECUTOR ANTHONY PRESTOZA: Did you not develop any ill feelings
towards your best friend when you learned that she and Ritchie is getting married?
IRIS VICTORIA MERIN: No, Your Honor. In fact, Im happy for the both of them.
PROSECUTOR ANTHONY PRESTOZA: No further questions, Your Honor.
COURT: Re-direct?
ATTY. TAPIRE: No, Your Honor.
COURT: Miss Witness, You may step down. Formal Offer of Evidence of Defense
ATTY. OCAMPO: Your Honor, we are now resting the case for the defense.
COURT: How do you intend to submit your formal offer?
ATTY. OCAMPO: We can now formally offer our evidence Your Honor.
PROSECUTOR ANTHONY PRESTOZA: Does he visit your apartment regularly?
COURT: Proceed.
IRIS VICTORIA MERIN: Yes, I think so.
ATTY. OCAMPO: Exhibit 1 is the Summary Discharge Report to prove the

complainants admission for treatment at the Medical Center Manila.
PROSECUTOR ANTHONY PRESTOZA: Do you entertain him when he visits

your place?
IRIS VICTORIA MERIN: Not at all. I usually give the couple some privacy.
PROSECUTOR ANTHONY PRESTOZA Did you like him?
Exhibit 2 is the Psychiatric Assessment issued by Dr. Leira Taruc to prove mental and
emotional condition of the complainant at the time she was admitted for psychiatric
treatment.
Exhibit 2-A is the signature by Dr. Leira Taruc as part of her testimony attesting to
the fact that she was the psychiatrist of the complainant at Medical Center Manila.
Exhibit 3 consists of printed copies of the electronic mails sent by the complainant to
witness Kate Nunez to prove the mental and emotional instability of the complainant
and her suicidal tendencies.
Exhibit 3-A is the printed copy of the electronic signature of the complainant to prove
the authorship of the electronic mails sent by her.
COURT: Any comment, Prosecutor Sarsaba?
PROSECUTOR ANTHONY PRESTOZA: As to Exhibit 1 and 1-A, we can admit
its existence and authenticity, Your Honor. As to Exhibit 2 and 2-A, we can only
admit the existence but not the authenticity and truthfulness Your Honor. Court:
Acting on the formal offer of exhibits of the defense counsel and comments thereon
by the public prosecutor, the Court resolves to admit all the exhibits offered by the
defense counsel specified in the offer.
COURT: Any rebuttal-evidence, Fiscal?
PROSECUTOR SARSABA: No rebuttal evidence, Your Honor.
COURT: Considering that the public prosecutor will not present rebuttal evidence,
the court gives the parties 30 days from today within which to file their respective
memoranda. The case shall be deemed submitted for decision after the lapse of the
said period, even without the said memorandum.
COURT: Order.

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SCRIPT Frustrated Murder

PROSECUTOR ANTHONY PRESTOZA: For the government.

People vs. Merin

ATTY. TAPIRE: For the defense.

Ayn Sarsaba -Prosecution Counsel

PROSECUTOR ANTHONY PRESTOZA: Ready Your Honor.

Anthony Prestoza - Prosecution Counsel

COURT: Call your witness to the witness stand.

Katherine Jane Manarang -Complainant

PROSECUTOR ANTHONY PRESTOZA: May I call on Catherine Jane Manarang.

Richard Alvin Nalupta- Boyfriend of the Complainant (Prosecution Witness)

Analita Ocampo -Defense Counsel

WITNESS: Yes, sir.

Helen Paulette Tapire- Defense Counsel

COURT: Please state your name and other personal circumstances.

Iris Victoria Merin - Accused

COURT: Call the case.

WITNESS: Catherine Jane Manarang, 28 years of age, single, a Certified Public

DIRECT EXAMINATION OF CATHERINE JANE

COURT: Swear in the witness.

PROSECUTOR ANTHONY PRESTOZA: The witness is being presented to testify

CATHERINE JANE MANARANG: I was in our apartment at Unit 143 Astral

PROSECUTOR PRESTOZA: Which for purposes of identification, Your Honor, I

CATHERINE JANE MANARANG: Yes, Your Honor.

COURT: Mark it.

PROSECUTOR ANTHONY PRESTOZA: What did you do in order to solve the

PROSECUTOR ANTHONY PRESTOZA: And the signature appearing above the

CATHERINE JANE MANARANG: I used a rat killer, Your Honor.

COURT: Mark it.

PROSECUTOR ANTHONY PRESTOZA: Who bought the rat killer?

PROSECUTOR ANTHONY PRESTOZA: We would also like to request for the

COURT: Mark it.

PROSECUTOR ANTHONY PRESTOZA: Was there consistent compliance by the

PROSECUTOR ANTHONY PRESTOZA: What else did you do on that day?

CATHERINE JANE MANARANG: Yes, thats the one.

CATHERINE JANE MANARANG: She told me that I was just tired.

PROSECUTOR ANTHONY PRESTOZA: For the record, the pitcher, previously

PROSECUTOR ANTHONY PRESTOZA: What time did you leave Starbucks?

CATHERINE JANE MANARANG: 5 oclock

CATHERINE JANE MANARANG: I drank about 2 glasses.

CATHERINE JANE MANARANG: The guests arrived. We entertained them.

PROSECUTOR ANTHONY PRESTOZA: Can you estimate the amount of juice

PROSECUTOR ANTHONY PRESTOZA: Was your fiance with them?

CATHERINE JANE MANARANG: A glass would contain about 300-350 mL of

CATHERINE JANE MANARANG: Yes.

CATHERINE JANE MANARANG: I approached Iris and chatted with her.

PROSECUTOR ANTHONY PRESTOZA: Did anyone come to help?

CATHERINE JANE MANARANG: Yes.

PROSECUTOR ANTHONY PRESTOZA: Did you notice anything else?

CATHERINE JANE MANARANG: Before I totally lost consciousness, I saw that

PROSECUTOR ANTHONY PRESTOZA: So, if the accused is inside this

ATTY. OCAMPO: Yes, Your Honor.

CATHERINE JANE MANARANG: Yes, Your Honor.

CROSS EXAMINATION OF CATHERINE JANE

CATHERINE JANE MANARANG: Yes, Your Honor.

CATHERINE JANE MANARANG: Yes, Your Honor.

CATHERINE JANE MANARANG: A bit blurry, Your Honor.

CATHERINE JANE MANARANG: Yes, Your Honor. Both of us used to do that.

ATTY. ANALITA OCAMPO: Was your sight still clear?

CATHERINE JANE MANARANG: Yes, Your Honor.

CATHERINE JANE MANARANG: Im not sure Your Honor.

ATTY. ANALITA OCAMPO: When was this?

ATTY. ANALITA OCAMPO: Who prepared this medical report?