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    Certificate of Death

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    Janine Garcia
    This document is a pre-trial brief submitted by prosecutors in a criminal case against two police officers accused of frustrated murder and sexual abuse of a minor. It summarizes admitted facts such as the identities of those involved and dates of the alleged crimes. It also lists proposed evidence like affidavits and forensic reports, the issues to be addressed in trial, and witnesses who will testify regarding the illegal arrest and cause of death of the victim. The prosecutors request that trials be held on Fridays and provide their contact information.

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    Certificate of Death

    Uploaded by

    Janine Garcia
    63 views3 pages
    This document is a pre-trial brief submitted by prosecutors in a criminal case against two police officers accused of frustrated murder and sexual abuse of a minor. It summarizes admitted facts such as the identities of those involved and dates of the alleged crimes. It also lists proposed evidence like affidavits and forensic reports, the issues to be addressed in trial, and witnesses who will testify regarding the illegal arrest and cause of death of the victim. The prosecutors request that trials be held on Fridays and provide their contact information.

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    This document is a pre-trial brief submitted by prosecutors in a criminal case against two police officers accused of frustrated murder and sexual abuse of a minor. It summarizes admitted facts such as the identities of those involved and dates of the alleged crimes. It also lists proposed evidence like affidavits and forensic reports, the issues to be addressed in trial, and witnesses who will testify regarding the illegal arrest and cause of death of the victim. The prosecutors request that trials be held on Fridays and provide their contact information.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    63 views3 pages

    Certificate of Death

    Uploaded by

    Janine Garcia
    This document is a pre-trial brief submitted by prosecutors in a criminal case against two police officers accused of frustrated murder and sexual abuse of a minor. It summarizes admitted facts such as the identities of those involved and dates of the alleged crimes. It also lists proposed evidence like affidavits and forensic reports, the issues to be addressed in trial, and witnesses who will testify regarding the illegal arrest and cause of death of the victim. The prosecutors request that trials be held on Fridays and provide their contact information.

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    Republic of the Philippines

    Sixth Judicial Region


    REGIONAL TRIAL COURT
    Branch___
    Roxas City

    PEOPLE OF THE
    PHILIPPINES Criminal case no.: 123
    Plaintiff, For: Violation of Art. 248 of
    the Revised Penal Code
    -versus- otherwise known as
    Frustrated Murder,and
    Sexual Abuse on a minor
    PO2 ALIPIO BALO and PO1
    MICHAEL TOMAS

    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 Jaypee Bertes and his father, the victim;
    3. the killing of the victim;
    4.the identity of the two-year child, the victim of abuse; and
    5. the date and places of the commission of the crime.
    EVIDENCE FOR MARKINGS
    1. Affidavit of the neighbor Juan Dela Cruz
    Purpose: to prove that he was already inside his house with his family when the
    killing took place and that the accused barged his house in the middle of the
    night;
    2. Affidavit of the Barangay Chairma Luis Mantal
    Purpose: to certify that Jaypee Bertes was arrested without a warrant in their
    barangay when the crime happened and that he saw what happened that night;
    3. Affidavit of Hanna Kazuo
    Purpose: to prove that the arrest was illegal and to narrate the true story behind
    the said crime;
    3. Autopsy Report of Manish Agarwal, M.D. assisted by Victoria Witte,
    M.D.conducted
    Purpose: to prove the extent of the injury and the cause of death of the victim;
    4. Paraffin test result
    Purpose: To prove that accused became positive of gun powder burns.
    5. Anatomical Sketch
    Purpose: To prove which part of the victims body was shot and the nature,
    extent and location of wound.
    6.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 one of the policemen in
    Pasay Station
    7. Fired Shell
    8. Three live ammunitions
    9. .45 caliber pistol
    ISSUES
    1. Whether or not the accused committed the crime charged;
    2. Whether or not they were guilty thereof.
    WITNESSES
    1. Juan De La Cruz to testify that the arrest in the house of Bertes on the
    said time of the arrest;
    2. Chairman Luis Mantal to certify that Jaypee Bertes was arrested
    without a warrant in their barangay when the crime happened and that he saw
    what happened that night;
    3. Hanna Kazuo to prove that the arrest was illegal and to narrate the
    true story behind the said crime;
    4. Manish Agarwal, M.D. assisted by Victoria Witte, M.D. to prove the extent of
    the injury and the cause of death of the victim; and D to testify that she
    conducted the post mortem examination of Jaypee Bertes and to attest to the
    veracity of her findings in the autopsy report.

    5. ChaCha Yu testify that he was the police officer who went to the scene
    of the crime and arrested the accused.

    6. Police Senior Inspector Tony Pet to testify that he conducted the


    ballistics examination and to attest to the veracity of his findings in the said
    report.
    7. Chemist Dionisia Pacquio 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.
    Pasay City, Philippines, November 5, 2016.

    PASAY CITY PROSECUTORS OFFICE

    By:

    JC DE VERA
    Assistant City Prosecutor
    Roll No. 67890 / 5-2-07
    IBP. No. 667899 / 12-29-07
    MCLE Exempt
    PTR Exempt

    And

    RURU MADRID
    Assistant City Prosecutor
    Roll No. 67891 / 5-2-07
    IBP No. 667900 / 12-29-07
    MCLE Exempt
    PTR Exempt
    Copy furnished:

    ATTY. DENNIS TRILLO


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

    Received by:___________
    Date: ___________

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