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(Information for Serious Physical Injuries)

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INFORMATION

The undersigned, _____________, accuses _____________ of the crime of SERIOUS PHYSICAL INJURIES, committed as
follows, to wit:

That on or about _____________, at about _________ (a.m./p.m.), in the City/Municipality of _____________, Province of
_____________ and within the jurisdiction of this Honorable Court, the said accused did there and then willfully, unlawfully and
feloniously, and without justifiable cause therefor, attack, assault, and beat one _____________ with a baseball bat, resulting to
injuries to the latter rendering him in capacitated for labor for a period of more than thirty (30) days.

Contrary to law.

_____________, Philippines, __Date__.

PROSECUTOR

Witnesses:

____________________
____________________

(Certification of Preliminary Investigation)

____________________ ____________________
Republic of the Philippines
Sixth Judicial Region
REGIONAL TRIAL COURT
Branch___
Iloilo City
PEOPLE OF THE PHILIPPINES, CRIMINAL CASE NO._______
Plaintiff, FOR:
ROBBERY WITH HOMICIDE
- versus –

TITO CRUZ AND VIC CRUZ,


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 Joey Cruz, 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 Geraldine Demetri

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 Bea Robles


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 Paris Michaels

Purpose: to corroborate the testimonies of Geraldine Demetri and Bea Robles;

3. Autopsy Report of Joey Cruz 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 Jaro Police Station (ICP-PP3)
Purpose: to prove that the police authority received a report that a robbery took
place at Iloilo Supermart, located at Tabuk Suba, Jaro, Iloilo City.

5. Affidavit of Romeo V. Benamarca

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 victim’s body was shot and the nature,
extent and location of wound.
8. Ballistics Test result
Purpose: To prove that the slug recovered from the victim’s body came from the

same gun which was recovered from the possession of Tito Cruz.

9. Fired Shell

10. Three live ammunitions

11. .45 caliber pistol

I S S U E S

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


2. Whether or not they were guilty thereof.
W I T N E S S E S

1. Geraldine Demetri to testify that a robbery took place;


2. Bea Robles to testify that she was one of the customers of the Iloilo
Supermart at the time the robbery took place;
3. Paris Michaels to testify that she was one of the customers of Iloilo
Supemart at the time the robbery took place.
4. Romeo V. Benamarca to testify that he was the police officer who went
to the scene of the crime and arrested the accused.

5. Dra. Isabel Cenon 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 Anthony Villar to testify that he conducted the ballistics examination and to attest to the

veracity of his findings in the said report.7. Chemist Dionisia Paqui to testify that she conducted a paraffin test to

the accused and to attest to the veracity of her findings in the said report.
T RIAL DATES

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

Iloilo City, Iloilo, Philippines, July 4, 2008.

ILOILO CITY PROSECUTOR’S OFFICE


Ramon Q. Avanceña Hall of Justice
Bonifacio Drive,Iloilo City
By:

JOHN FRED C. HALLARES

Assistant City Prosecutor


Roll No. 67890 / 5-2-07
IBP. No. 667899 / 12-29-07
MCLE Exempt
PTR Exempt

And

JASIE ANN MAGHOPOY

Assistant City Prosecutor


Roll No. 67891 / 5-2-07
IBP No. 667900 / 12-29-07
MCLE Exempt
PTR Exempt

Copy furnished:
ATTY. KENETH P. TUPAS

Counsel for the Defense


Room 200, New Valentine Bldg.
Central Philippine University
Lopez Jaena St., Jaro, Iloilo City

Received by:___________
Date: ___________
Republic of the Philippines
Sixth Judicial Region
REGIONAL TRIAL COURT
Branch___
Iloilo City

PEOPLE OF THE PHILIPPINES, CRIMINAL CASE NO._______


Plaintiff, FOR: MURDER

- versus –

GABRIEL SALAS, ALFREDO GOLEZ,


AND GREG FAJARDO,
Accused.
x-----------------------------------------------x

PRE-TRIAL BRIEF OF THE ACCUSED

ACCUSED, through the undersigned counsel, before this Honorable Court,


most respectfully submit this Pre-Trial Brief:

SUMMARY OF ADMITTED FACTS


AND PROPOSED STIPULATION OF FACTS

The accused admit the following:


1. the identities of those charged in the information and that of the

persons arraigned are one and the same;

2. the identity of Sulpicio Treyes, the victim;

3. the killing of the victim;

4. the date, place and time of the killing, which was May 5, 2008 at about
1:30 in the morning and at Corner Valeria-De Leon Sts., Iloilo City.

EVIDENCE FOR MARKINGS

1. Affidavit of accused, Gabriel Salas

Purpose: to prove that he admits the killing of the victim but the same was done

in self-defense;

2. Affidavits of accused, Greg Fajardo and Alfredo Golez


Purpose: to prove that they were at the place where the crime was committed
but have no participation thereof;
3. Medical Report issued by Dra. Cielo F. Eltonn, M.D. to Gabriel Salas
Purpose: to prove that the accused sustained several wounds as a result of the
aggression by the victim;
4. Blotter Report of Molo Police Station (ICP-PP4)

Purpose: to prove that the accused Gabriel Salas voluntarily surrendered to the
Police authorities.
I S S U E S

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


2.Whether or not they were guilty thereof.

W I T N E S S E S

1. Accused Gabriel Salas to testify on the matters and circumstances


attending the killing of the victim;
2. Accused Alfredo Golez and Greg Fajardo to testify on their non-
participation on the killing;

3. Witness Jason Pilas-Pilas to testify on the exchange of words and blows between the accused Gabriel Salas and the

deceased which resulted to the death of the victim;

4. Dra. Cielo F. Eltonn, M.D. to testify on the veracity of the findings


stated in the medical report of Gabriel Salas.

T RIAL DATES

Specifically all Fridays of the month, with the regular appearance of the
undersigned counsels before this Honorable Court.

RESPECTFULLY SUBMITTED.

Iloilo City, Iloilo, Philippines, June 2, 2008

GALLEGO-SABIDO LAW OFFICES


Arguelles St., Jaro, Iloilo City
By:
RHONALYN C. GALLEGO

Counsel for the Defense


Roll No. 68999 / 5-2-07
IBP. No. 789084 / 12-29-07
MCLE Compliance No. 890590 / 12-20-07
PTR No. 345667 / 01-05-08

And
EVANGELINE S. SABIDO

Counsel for the Defense


Roll No. 69009 / 5-2-07
IBP. No. 789085 / 12-29-07
MCLE Compliance No. 890591 / 12-20-07
PTR no. 345668 / 01-05-08
Copy furnished:

PROS. SHYR PHOEBE F. REGUETA

Assistant City Prosecutor


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

Received by:___________
Date: ___________

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