REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

LUCENA CITY

BRANCH___________

PEOPLE OF THE PHILIPPINES CRIMINAL CASE NO._____________

Plaintiff (NPS Docket No. _______________)

-versus- -for-

ROBBERY

ATTY. SIR CHIEF, JINGGOY,

JUAN AND JOAQUIN

Accused

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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 Maya, the victim;
3. The date, and place of the commission of the crime;
4. The robbery was committed by means of conspiracy;
5. The recovery of the 10 trays of jewelry allegedly owned by Maya, the victim;
6. The recovery of the walkie-talkies used by Atty.Sir Chief ,Jinggoy, and Juan;
7. Walkie-talkie of Emerson Calatrava which he surrendered voluntarily.

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 EVIDENCE FOR MARKINGS

1. Police Blotter Report of SPO1 Rommel Alday

Purpose: To prove that the police authority received a report that a robbery took
place at the residence of Maya situated at Lucena City.

2. Affidavit of Emerson Calatrava, Mayas neighbor.

Purpose: To describe the scene of the crime the next day that it was discovered and
describe the conversation he intercepted in his walkie talkie.

3. Affidavit of CCTV Operator Ricardo Oabel

Purpose: To prove that the video footage is authentic.

4. 10 trays of jewelries recovered

Purpose: To prove that the recovered jewelries are of the same kind belonging to
the victim, Maya.

5. CCTV Video Footage

Purpose: To prove that the suspects are indeed the same persons caught in the
video footage at the scene of the crime

6. Walkie Talkies recovered from Sir Chief, Jinggoy, Juan and Joaquin

Purpose: To prove it was used to command the execution of the crime.

7. Walkie-Talkie of Emerson Calatrava

Purpose: To prove to the identity and conspiracy of Atty. Sir Chief, Joaquin, Jinggoy
and Juan in committing the crime

ISSUES

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

2. Whether or not they were guilty thereof.

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 WITNESSES

1.) Police Senior Inspector Rommel Alday - to testify that he had received a report of
robbery at the residence of Maya.

2.) CCTV Operator Ricardo Oabel to testify that the video footage was genuine and to
identify the suspects are the same persons caught on camera.

3.) Emerson Calatrava- to testify that he saw body of Maya the next day the crime was
committed and to testify to the truth of the conspiracy because he intercepted a signal
from his own walkie talkie the conversation of Atty. Sir Chief, Jinggoy, Juan and Joaquin

TRIAL DATES

Specifically all Mondays of the month, with regular appearance of the undersigned City
Prosecutors before this Honorable Court.

RESPECTFULLY SUBMITTED.

Lucena City, Philippines, July 29, 2017

LUCENA CITY PROSECUTORSS OFFICE

BY:

ATTY.TIMOTHY MARK G. MADERAZO

Assistant City Prosecutor

And

ATTY. ALBERT A. MARQUEZ

Assistant City Prosecutor

ATTY.ARJAY ALFPED SALAMILLAS

City Prosecutor

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Cc:

ATTY.DENNIS RAMIREZ
ATTY.EDELYN AYANGCO
ATTY.JOHN MARK SAPORNA
Counsels for the Defense

Received by:____________

Date: _________________

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