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    8.pre Trial Brief Sample

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    Emaleth Lasher
    1) This document is a pre-trial brief submitted by prosecutors for a case of reckless imprudence against Tito Cruz and Vic Cruz. It summarizes the admitted facts of the case and identities of those involved. 2) The prosecution lists the evidence that will be presented, including affidavits from eyewitnesses and autopsy/ballistics reports. They intend to prove the accused committed robbery and killed the victim. 3) The issues to be addressed are whether the accused committed the charged crime and whether they are guilty. Witnesses include eyewitnesses, investigating officers, and medical experts to authenticate reports. Trial dates are scheduled for Fridays of each month.

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    © All Rights Reserved
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    8.pre Trial Brief Sample

    Uploaded by

    Emaleth Lasher
    245 views3 pages
    1) This document is a pre-trial brief submitted by prosecutors for a case of reckless imprudence against Tito Cruz and Vic Cruz. It summarizes the admitted facts of the case and identities of those involved. 2) The prosecution lists the evidence that will be presented, including affidavits from eyewitnesses and autopsy/ballistics reports. They intend to prove the accused committed robbery and killed the victim. 3) The issues to be addressed are whether the accused committed the charged crime and whether they are guilty. Witnesses include eyewitnesses, investigating officers, and medical experts to authenticate reports. Trial dates are scheduled for Fridays of each month.

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    1) This document is a pre-trial brief submitted by prosecutors for a case of reckless imprudence against Tito Cruz and Vic Cruz. It summarizes the admitted facts of the case and identities of those involved. 2) The prosecution lists the evidence that will be presented, including affidavits from eyewitnesses and autopsy/ballistics reports. They intend to prove the accused committed robbery and killed the victim. 3) The issues to be addressed are whether the accused committed the charged crime and whether they are guilty. Witnesses include eyewitnesses, investigating officers, and medical experts to authenticate reports. Trial dates are scheduled for Fridays of each month.

    Copyright:

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

    8.pre Trial Brief Sample

    Uploaded by

    Emaleth Lasher
    1) This document is a pre-trial brief submitted by prosecutors for a case of reckless imprudence against Tito Cruz and Vic Cruz. It summarizes the admitted facts of the case and identities of those involved. 2) The prosecution lists the evidence that will be presented, including affidavits from eyewitnesses and autopsy/ballistics reports. They intend to prove the accused committed robbery and killed the victim. 3) The issues to be addressed are whether the accused committed the charged crime and whether they are guilty. Witnesses include eyewitnesses, investigating officers, and medical experts to authenticate reports. Trial dates are scheduled for Fridays of each month.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 3

    Republic of the Philippines

    Sixth Judicial Region


    REGIONAL TRIAL COURT
    Branch 15
    Roxas City
    PEOPLE OF THE PHILIPPINES,
    Plaintiff,

    CIVIL CASE NO.123456A


    FOR:
    RECKLESS IMPRUDENCE

    - 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 victims body was shot and the nature,
    extent and location of wound.
    8. Ballistics Test result
    Purpose: To prove that the slug recovered from the victims body came from the
    same gun which was recovered from the possession of Tito Cruz.
    9. Fired Shell
    10. Three live ammunitions
    11. .45 caliber pistol
    ISSUES
    1.

    Whether or not the accused committed the crime charged;

    2.

    Whether or not they were guilty thereof.


    WITNESSES

    1. 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.
    TRIAL 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 PROSECUTORS OFFICE


    Ramon Q. Avancea 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: ___________

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