Case Folder Santos1
Case Folder Santos1
Case Folder Santos1
FROM
: COP, SFPS
_______________________
P/SUPT Vernon Yutuc
COP, SFPS
FROM
: COP, SFPS
1. Request conduct for Genital Examination of the person Criselda Sogue Y Dizon,
Single 18 years old residing at San Nicholas, City of San Fernando Pampanga.
2. In connection with paragraph 1 above, request furnish this office a copy of the
initial request thereof for reference purposes.
3. For consideration.
_______________________
P/SUPT Vernon Yutuc
COP, SFPS
FROM
: COP, SFPS
1.
2.
3. For consideration.
________________
P/SUPT Vernon Yutuc
COP, SFPS
FROM
: COP, SFPS
3. For consideration.
________________
P/SUPT Vernon Yutuc
COP, SFPS
FROM
: COP, SFPS
1. References:
a. PROGRESS REPORT
b. FINAL REPORT
2. Per above references, request conduct fingerprint identification/latent
print lifting and identification /fingerprint comparison on the herein
submitted specimen to that of the standard fingerprint taken from the
suspect Mr. Raffy Guinto to wit:
a. Standard fingerprint specimen of Mr. Raffy Guinto; and
b. Questioned latent prints recovered in a knife placed in a zip
lock with markings.
3. Further request furnish this Division result thereof for our investigative
reference.
________________
P/SUPT Vernon Yutuc
COP, SFPS
FROM
: COP, SFPS
1. Request for the presence of SOCO Team to process the crime scene
located at HS Boulevard, Lourdes City of San Fernando Pampanga.
a. NATURE OF CASE
: Rape with Homicide
b. VICTIM
: Criselda D. Sogue
c. SUSPECT
: Raffy Guinto
d. TDPO
: 7:00 PM of July 30, 2015 at Boulevard, Lourdes
City of San Fernando Pampanga.
2. Further request that this Office be furnished a copy of medico-legal
examination result for our references.
3. For consideration.
________________
P/SUPT Vernon Yutuc
COP, SFPS
Complainant/s:
1. PO1 Erick Mercado
Respondent
1. Raffy Guinto
Address: Lourdes City of San Fernando
Witnesses:
Name: Jaicel Jimenez
Address: San Nicholas, City of San
Fernando
NOTE:
1. Has a similar complaint been filed before any other office? (YES or NO)
2. Is this complaint in the nature of a counter charge? (YES or NO)
3. Are all the above informations true and correct? (YES or NO)
IMPORTANT
Complainant shall be required to file his complaint in the form of an affidavit to which
must be appended affidavit of witnesses, annexes and other supporting documents.
The statements of the complainant and his witnesses shall, as far as practicable, be
sworn to before the Investigating Prosecutor. If sworn to before any Officer authorized
to administer oaths, the administering Officer shall CERTIFY THAT HE HAS
PERSONNALY EXAMINED THE AFFIANT AND THAT HE VOLUNTARILY EXECUTED
AND UNDERSTOOD HIS AFFIDAVIT.
_________________________________
Vs
Raffy Guinto
x-----------------------x
COMPLAINT
The undersigned, Chief of Police P/SUPT Vernon Yutuc, accuses
Guinto in the Municipality of San Fernando Pampanga, province of Pampanga,
Philippines; the said accused did then and there, willfully, unlawfully, and feloniously,
with malice and aforethought, raped and stabbed Criselda D. Sogue, wounding the
latter in the upper abdomen, producing wounds which are fatal, thereby causing the
immediate death of said victim.
Contrary to law.
_______________________
P/SUPT Vernon Yutuc
COP, SFPS
SUBSCRIBED AND SWORN before me this 2nd day of August 2015 in the province of
Pampanga.
________________
JUDGE
x--------------------------------------------------------------x
AFFIDAVIT OF WITNESS
I, Jaicel Jimenez, 19 years old, single, resident of San Nicholas, City of San
Fernando, after having sworn in accordance with law, do hereby depose and state
THAT:
1. I was present and personally saw that the accused is present in the crime scene.
That he committed the crime of rape with homicide against the victim Criselda D.
Sogue.
2. That we saw the victim lying unresponsively in the place of the commission of the
crime.
3. That at about 6:30 PM of July 30, 2015 me and Maeleen Ferrer is heading home
when we saw the victims bag in the middle of the lane and just steps away is the
victims undressed body lying and full of blood.
4. On which on the same state a man named Raffy Guinto breathing hardly and
suddenly ran away from the crime scene.
I executed this affidavit to attest the truthfulness of the foregoing facts and
to support the filing of Criminal Cases against Raffy Guinto for violations of
Rape with Homicide.
AFFIANTS SAYETH NAUGHT.
SUBSCRIBED AND SWORN to before me this 2nd day of August 2015 at the City of
San Fernando. I HEREBY CERITIFY that I have personally examined the herein
affiants and I am satisfied that they voluntarily executed and understood their given
affidavit.
________________
Notary Public
AFFIDAVIT OF WITNESS
I, Maeleen Ferrer single 21 years old, single, and a resident of San Nicolas City
of San Fernando, after having sworn in accordance with law, do hereby depose and
state THAT:
1. I was present and personally saw that the accused is present in the crime scene.
That he committed the crime of rape with homicide against the victim Criselda D.
Sogue.
2. That we saw the victim lying unresponsively in the place of the commission of the
crime.
3. That at about 6:30 PM of July 30, 2015 me and Jaicel Jimenez is heading home
when we saw the victims bag in the middle of the lane and just steps away is the
victims undressed body lying and full of blood.
4. On which on the same state a man named Raffy Guinto breathing hardly and
suddenly ran away from the crime scene.
I executed this affidavit to attest the truthfulness of the foregoing facts and
to support the filing of Criminal Cases against Raffy Guinto
Guinto for violations of Rape with Homicide.
SUBSCRIBED AND SWORN to before me this 2nd day of August 2015 at the City of
San Fernando. I HEREBY CERITIFY that I have personally examined the herein
affiants and I am satisfied that they voluntarily executed and understood their given
affidavit.
________________
Notary Public
Presiding Judge
TECHNICAL WRITING
(CASE FOLDER)
CASE FOLDER OF
a. NATURE OF CASE : Rape with Homicide
b. VICTIM
: Criselda D. Sogue
c. SUSPECT
: Raffy Guinto
ENCLOSURES OF CASE REFERRAL/TRANSMITTAL
TABLE OF CONTENTS
4. Documentary Evidence
D-1
D-2
D-3
d. Summary of Information
D-4
e. Coordination
D-5
D-6
D-7
D-8
D-9
D-10
D-11
D-12
D-13
n. Others
D-14
______________________
IOC, PO2 Lyca C. Alejandrino
Noted By:
________________
P/SUPT Vernon Yutuc
COP, SFPS
FROM
I.
II.
At about 7:00 PM of July 30, 2015 an alleged Rape with Homicide was
reported in our office by Patrol officers on duty PO1 Erick Mercado and PO2
Joward Tua at HS Boulevard, Lourdes City of San Fernando Pampanga. That
at the same time and date while the officers are patrolling across Sto. Nino,
City of San Fernando and HS Boulevard, Lourdes City of San Fernando
Pampanga boundary, a concern citizen named Jaicel Jimenez single 19 years
old, and a resident of San Nicholas, City of San Fernando seek for their help to
rescue the victim named Criselda Sogue single 18 years old, resident of San
Nicholas, City of San Fernando Pampanga.
III.
IV.
MEMORANDUM
FOR
FROM
DATE
: August 5, 2015
I.
References:
A. Blotter, SFPS dated July 30, 2015
B. Spot Report, SFPS dated July 31, 2015
II.
San Fernando Police Station lead by PO1 Erick Mercado and PO2 Joward
Tua conducted the arrest that eventually resulted to the apprehension of Raffy
Guinto single 21 years old, and a resident of Barangay Lourdes City of San
Fernando, suspect immediately proceeded to the custody of San Fernando
Police Station and returned the warrant of arrest to the Regional Trial Court,
Branch 1 City of San Fernando Pampanga.
III.
FROM
I.
References:
A. Blotter, SFPS dated July 30, 2015
B. Spot Report, SFPS dated July 31, 2015
C. Progress Report, SFPS dated August 5, 2015
II.
A Rape case with Homicide happened on or about 7:00 PM July 31, 2015 at
HS Boulevard Lourdes, City of San Fernando Pampanga.
III.
The case Rape with Homicide was filed against Mr. Raffy Guinto single 21
years old, and a resident of Barangay Lourdes City of San Fernando in
Regional Trial Court Branch 1 City of San Fernando Pampanga. The accused
was transferred to the Provincial Jail in Capitol City of San Fernando
Pampanga while waiting for the trial.
IV.
_______________________
P/SUPT Vernon Yutuc
COP, SFPS
committed).
On the complaint dated July 31, 2015, (state the act and the crime
04.
Upon receipt of their said complaint, our office planned out an
entrapment operation against the suspect. At about _8:00 AM__ of August 5, 2015_, the
undersigned together with the complainant proceeded at the pre-arranged pay off RTC
Branch 1_ located along San Fernando Pampanga_ to give the money being asked by
the respondent;
05.
Upon arrival thereat, complainants waited for the suspect to arrive
while we the undersigned seated near the table of the complainants. At about 8:20 AM,
suspect arrived and approached the complainants and after few conversation,
complainants handed over the marked money to the suspect that minutes of prompted
the undersigned to immediately effect arrest;
06.
Seized and recovered in the possession and control of the arrested
person were the following, to wit:
07.
Suspect together with the seized and recovered evidence was brought
to the San Fernando Police Station 8:00 AM_, August 5, 2015 for booking and proper
disposition. Likewise, the arrested person was apprised of their rights as provided for
under the Constitution of the Philippines.
08.
The report of the PNP Crime Laboratory Group Physical Identification
Report No. 0998_______ dated July 31, 2015_, revealed that suspect
______________________ was POSITIVE for the presence of Bright Yellow Ultraviolet
Fluorescent powder on both palm and right dorsal portion of the hands.
We executed this joint affidavit to attest the truthfulness of the foregoing facts and
to support the filing of Criminal Cases against Raffy Guinto for violations of Rape With
Homicide.
AFFIANTS SAYETH NAUGHT.
IN WITNESS WHEREOF, we hereunto affixed our signature this 05 day of
August at RTC Branch 1 City of San Fernando Pampanga.
Maria Sogue_______
Affiant
Date:August
05,
2015_
1. REPORTED THRU:
[ ] In Person
[ ] Telephone
[ ] Other
3. Nature of Complaint/Info
Rape With Homicide
4. Place of Occurrence/Incident
Bren Z Guiao Convention Center City of
San Fernando Pampanga
6. Name of Complainant/Informer
Maria Sogue
7. Address
8. Tel No.
Brgy San Nicolas City of San Fernando 09169822134
Pampanga
9. Name(s) of Victim(s)
Criselda Sogue
11.Sex
10. Age
18 yrs
old
15. Alias
Raffy
12. Address
5. Date/time
July 31, 2015, 7
Female
20. Address
21. Tel N
Brgy San Nicolas City of San Fernando 0916982
Jaicel Joy Jimenez
Pampanga
None
Maeleen Ferrrer
Brgy Sta Ana Mexico Pampanga
22. Brief facts/narrative of complaint (Use back page, if necessary)
The witness with her company Maeleen Ferrer single 21 years old,and a resident of _ City of San F
heading home when they saw the victims bag in the middle of the lane and just steps away is the vic
undressed body lying and full of blood. On which on the same state a man named Raffy Guinto brea
and suddenly ran away from the crime scene.
Date/Time/Complaint/Info Received
August 06, 2015, 8:30 AM
PO1Erick Mercado
CONFIDENTIAL
FROM
SUBJECT
DATE
1.
Request conduct examination on the person of Raffy Guinto, 21 yrs old,
single and a resident of Brgy Lourdes City of San Fernando Pampanga who was
arrested during entrapment operation conducted at about (8:00 PM) in the evening at
Brgy Lourdes City of San Fernando Pampanga.
a)
b)
VICTIM
: Criselda Sogue
c)
SUSPECT
: Raffy Guinto
d)
TDPO
:At about
Guiao Convention Center
e)
2.
Further request that this Office be furnished a copy of examination result
for our reference.
3.
For consideration.
________________
P/SUPT Vernon Yutuc
COP, SFPS
TANONG SAGOT
03.
TANONG SAGOT
04.
T S -
05.
T S -
06.
T S -
07.
T S -
08.
T S -
09.
T -
S -
10.
T S -
Pahina 2.
Karugtong ng malaya at kusang loob na
____________________________, ngayong ika-___ ng _____, 20___.
11.
T S -
12.
T -
salaysay
ni
Bukod sa iyo, may mga alam ka bang mga tao na nakakita ng naturang
krimen________________?
Opo si Maeleen Ferrer at si Jaicel Joy Jimenez
S -
Ano naman ang iyong ginawa matapos mong masaksihan ang naturang
insidente?
humingi ng tulong sa mga pulis
13.
T S -
14.
T -
S 15.
T S -
16.
T S -
__________________________________________
(IF
INJURED,
DIAGNOSIS
OF
THEATTENDING
PHYSICIAN AND NAME OF HOSPITAL)
DATE/TIME/PLACE :
OF OCCURRENCE :
SUSPECTS
:
EVIDENCE
WITNESSES
:
:
On or about 7:00 PM of July 30, 2015 an alleged Rape with Homicide was reported in
our office by Patrol officers on duty PO1 Erick Mercado and PO2 Joward Tua at High
School Boulevard, Lourdes City of San Fernando Pampanga. At the same time and
date while the officers are patrolling in Sto. Nino, City of San Fernando and HS
Boulevard, Lourdes City of San Fernando Pampanga, a friend of victim named Jaicel
Jimenez, single, 19 years old, and a resident of San Nicolas, City of San Fernando seek
for their help to rescue the victim named Criselda Sogue single 18 years old, resident of
San Nicolas, City of San Fernando Pampanga.
Lyca Alejandrino______________
NAME OF OFFICER-ON-CASE
____
PO2_______________________
RANK
PNP
___
Investigator on Case_________
DESIGNATION
Picture
2x2
(First Name)
(Middle Name)
ADDRESS :Brgy. Lourdes City of San Fernando Pampanga_ Tel No. 09169822132
PLACE & DATE OF BIRTH : JBL Hospital, March 3, 1996
OCCUPATION : NONE___________________ MARITAL STATUS : Single________________
NATIONALITY : Filipino____________ SEX : Male______ WEIGHT : 70 kg___ HEIGHT: 64_
AGE : 20_________EDUCATIONAL ATTAINMENT : Collge Student_____________________
NAME OF SCHOOL: CELTECH COLLEGE________LOCATION OF SCHOOL: HS Blvd CSFP
SCARS AND MARKS : NONE______________________ OTHER IDENTIFYING MARKS:NONE
NAME & ADDRESS OF FATHER: Joselito Guinto, Brgy Loudes City of San Fernando Pampanga
NAME & ADDRESS OF MOTHER: Joselita Guinto, Brgy Lourdes City of San Fernando Pampanga
NAME & ADDRESS OF RELATIVES: Joselito Guinto, Brgy Loudes City of San Fernando Pampanga
OFFENSE CHARGE:
(CRIM/IS NO.)
RIGHT HAND
THUMB
LEFT HAND
INDEX
MIDDLE
RING
LITTLE
FOR
FROM
SUBJECT
SOCO Assistance
1. Request for the availability of SOCO Team to process the crime scene located at Bren Z
Guiao Brgy Lourdes City of San Fernado Pampanga.
NATURE OF CASE
2. This request is made with the assurance that the Duty Investigator/ Investigator-On-Case,
being in- charge of the Crime Scene shall remain and provide all the necessary security
and support to the SOCO Team during the whole process until after the crime scene is
released.
3. Further request that this Office be furnished a copy of the list of evidence gathered and the
result of the examination conducted thereon.
4. For consideration and approval.
For the Chief of Police:
PO2 Lyca_Alejandrino
(Duty Investigator/Investigator-On-Case)
July 31,2015
Date
THIS IS TO CERTIFY that the Crime Scene (CS) described hereunder was turned over
by the First Responder (FR) to the Duty Investigator /Investigator-On-Case (IOC) with the
following gathered information:
___________________________________________________________________
Rank and Names of First Responders: PO1 Erick Mercado and PO2 Joward Tua__
__________________________________________________________________
Time/Date Report of Incident was received by FRs: 7;00 PM,July 31, 2015________
__________________________________________________________________
Jaicel Joy Jimenez, and a resident of Brgy San Nicolas City of San Fernando Pampanga
and Maeleen Ferrer a resident of Sta Ana Mexico Pampanga
F. Names of Persons Who Entered the CS after the Arrival of FR and Prior to Arrival of
Investigator (Medics, Local Officials, etc) (Address/Contact Nr):
Brgy Captain Rusto Ryan Lacap, a resident of Brgy Lourdes City of San Fernando Pampanga
and also the baragay tanod for security purposes.
(Note: Use the overleaf or back page for extra entries)
G. List of Evidence That May Have Been Seized or Collected by the FR (If Any):
Description
Disposition
____________________________________
____________________________________
This further certifies that the Crime Scene and all the evidence therein by the FRs have
been properly secured and preserved and that all the information contained herein is true and
correct to the best of our ability:
Witnessed By:
Rank/Name/Designation of Officer/
Signature over Printed Name
CRIME REPORT
NATURE OF CASE
COMPLAINANT/VICTIM
Criselda Sogue________________________
(NAMES,
PERSONAL
CIRCUMSTANCES
OF
COMPLAINANT)
_____________________________________
(IN RAPE CASES, ENCLOSE THE
MEDICAL FINDING)
DATE/TIME/PLACE
OF OCCURENCE
SUSPECTS
Raffy Guinto_________________________________
(NAMES, PERSONAL CIRCUMSTANCES)
____________________________________________
DESCRIPTION, IF AT-LARGE
EVIDENCE
WITNESSES
At about 7:00 PM of July 30, 2015 an alleged Rape with Homicide was
reported in our office by Patrol officers on duty PO1 Erick Mercado and PO2
JowardTua at HS Boulevard, Lourdes City of San Fernando Pampanga. That
at the same time and date while the officers are patrolling acrossSto. Nino,
City of San Fernandoand HS Boulevard, Lourdes City of San Fernando
Pampanga boundary, a concern citizen named Jaicel Jimenez single 19 years
old, and a resident of San Nicholas, City of San Fernandoseek for their help to
rescue the victim named CriseldaSogue single 18 years old, resident of San
Nicholas, City of San Fernando Pampanga.
VI.
Lyca Alejandrino_________
NAME OF OFFICER-ON-CASE
______________PINSP____________________
RANK
PNP
INVESTIGATOR ON CASE ___________
DESIGNATION
PNP
CHIEF OF POLICE_________________
DESIGNATION
Republic of the Philippines
Department of the Interior and Local Government
PHILIPPINE NATIONAL POLICE
PAMPANGA PROVINCIAL OFFICE 3
San Fernando Police Station
COORDINATION FORM
PLACE OF OPERATION: Bren Z Guiao Convention Center, Brgy Lourdes City of San
Fernando Pampanga.
TEAM LEADER: PSUPT. Yutuc Vernon__________________________________
MEMBERS: PO1 Erick Mercado________________________________________
__________________________________________________________________
__________________________________________________________________
VEHICLE USED:
_______________________
_________________________________
_______________________
MEMORANDUM
FOR
FROM
SUBJECT
DATE
July 31,2015
1.
specimen.
b)
VICTIM
: Criselda Sogue
c)
SUSPECT
: Raffy Guinto
d)
TDPO
: At about 7:00 PM, July 31, 2015, Bren Z
Guiao Convention Center
e)
For consideration.
________________
P/SUPT Vernon Yutuc
COP, SFPS
MEMORANDUM
FOR
FROM
SUBJECT
DATE
July 31,2015
1.
Request conducts Genital Examination of the person Criselda Sogue_
residing at San Nicolas City of San Fernando Pampanga.
2.
In connection with para 1 above, request furnish this office a copy of the
initial result thereof for reference purposes.
________________
P/SUPT Vernon Yutuc
COP, SFPS
MEMORANDUM
FOR
FROM
DATE
AUTHORITY
1. Memo from that Office dated__July 31, 2015__re-investigation report
on the above subject.
2. Inherent
II
MATTERS TO BE INVESTIGATED
3. To determine the surrounding circumstances of the killing of the said
police officer.
4. To possibly identify the suspects that will led to their apprehension and
possible prosecution
III
IV
INVESTIGATION/FINDINGS
CONCLUSION
VI
RECOMMENDATION/DISPOSITION
________________
P/SUPT Vernon Yutuc
COP, SFPS
02.
03.
04.
05.
06.
07.
08.
TANONG -
SAGOT
Oo
TANONG -
SAGOT
Oo
TANONG -
SAGOT
T -
S -
T -
S -
T -
S -
Si Raffy Guinto po
T -
S -
T -
S -
Oo
09.
10.
T -
S -
Una po nakita naming yung bag ng kaibigan naming tapos bigla nalang po
naming nakita na ginagalaw na ni Raffy Guinto ang kaibigan namin.
T -
S -
Kutsilyo po
Pahina 2.
Karugtong ng malaya at kusang loob na
____________________________, ngayong ika-___ ng _____, 20___.
11.
12.
13.
14.
15.
16.
salaysay
ni
T -
Bukod sa iyo, may mga alam ka bang mga tao na nakakita ng naturang
krimen________________?
S -
T -
Ano naman ang iyong ginawa matapos mong masaksihan ang naturang
insidente?
S -
T -
S -
Opo
T -
S -
Wala na po
T -
S -
Hindi po
T -
S -
Opo
Nagsalaysay
SUBSCRIBED AND SWORN TO before me this July 31, 2015 at San Fernando Police
Station.
CERTIFICATION
I HEREBY CERTIFY THAT I have personally examined the herein affiant under oath and
that I am fully satisfied that he/she voluntarily executed and understood his/her statement.
________________________
Complainant,
-versus-
Raffy Guinto________________________
_________________________
Accused.
x------------------------------------------x
COMES NOW the complainant by the undersigned attorney and within the
reglementary period prescribed by the Rules of Court hereby files this motion for
reconsideration from the judgement of rendered by Mac Broke___ of RTC Branch 1_ by
virtue of newly found evidence which was not obtained during the trial of this case and if
produce will substantially affect the decision of the Honorable Court, to wit:
PRAYER
Atty. AC Macabrook____
(Attorney for the Complainant)
Atty.ABC Miserables______________
(Counsel for the Accused)
Atty.AC Macabrook______________
(Prosecutor on Case)
EXPLANATION
(Proof of Service)
________________________
Complainant-Appellant,
-versus-
For
Raffy Guinto_________________________
_Rape With Homicide__
Accused-Appellee,
x------------------------------------------x
NOTICE OF APPEAL
COMES NOW the complain by the undersigned attorney and within the
reglementary period prescribed by the Rules of Court hereby files this notice of appeal
from the judgement of dismissal rendered by Mac Broke_ of RTC Branch 1
10:00 AM______, _August 11, 2015_____, Regional Trial Court Branch 1 City of
San Fernando Pampanga.
Atty.ABC Miserables_____________
(Counsel for the Accused)
Republic of the Philippines
Department of the Interior and Local Government
PHILIPPINE NATIONAL POLICE
PAMPANGA POLICE OFFICE 3
San Fernando Police Station
MEMORANDUM
FOR
FROM
DATE
AUTHORITY
1. Memo from that Office dated__July 31, 2015__re-investigation report
on the above subject.
2. Inherent
II
MATTERS TO BE INVESTIGATED
3. To determine the surrounding circumstances of the killing of the said
police officer.
4. To possibly identify the suspects that will led to their apprehension and
possible prosecution
III
IV
INVESTIGATION/FINDINGS
CONCLUSION
VI
RECOMMENDATION/DISPOSITION
____________________
Chief of Office
02.
03.
04.
05.
06.
07.
08.
09.
TANONG -
SAGOT
Oo
TANONG -
SAGOT
Oo
TANONG -
SAGOT
T -
S -
T -
S -
T -
S -
Si Raffy Guinto po
T -
S -
T -
S -
Oo
T -
S -
Una po nakita naming yung bag ng kaibigan naming tapos bigla nalang po
naming nakita na ginagalaw na ni Raffy Guinto ang kaibigan namin.
10.
T -
S -
Kutsilyo po
Pahina 2.
Karugtong ng malaya at kusang loob na
____________________________, ngayong ika-___ ng _____, 20___.
11.
12.
13.
14.
15.
16.
salaysay
ni
T -
Bukod sa iyo, may mga alam ka bang mga tao na nakakita ng naturang
krimen________________?
S -
T -
Ano naman ang iyong ginawa matapos mong masaksihan ang naturang
insidente?
S -
T -
S -
Opo
T -
S -
Wala na po
T -
S -
Hindi po
T -
S -
Opo
SUBSCRIBED AND SWORN TO before me this July 31, 2015 at San Fernando Police
Station.
CERTIFICATION
I HEREBY CERTIFY THAT I have personally examined the herein affiant under oath and
that I am fully satisfied that he/she voluntarily executed and understood his/her statement.
_____________________
________________________
Complainant,
-versus-
Raffy Guinto________________________
_________________________
Accused.
x------------------------------------------x
COMES NOW the complainant by the undersigned attorney and within the
reglementary period prescribed by the Rules of Court hereby files this motion for
reconsideration from the judgement of rendered by Mac Broke___ of RTC Branch 1_ by
virtue of newly found evidence which was not obtained during the trial of this case and if
produce will substantially affect the decision of the Honorable Court, to wit:
PRAYER
Atty. AC Macabrook____
(Attorney for the Complainant)
Atty.ABC Miserables______________
(Counsel for the Accused)
Atty.AC Macabrook______________
(Prosecutor on Case)
EXPLANATION
(Proof of Service)
________________________
Complainant-Appellant,
-versus-
For
Raffy Guinto_________________________
_Rape With Homicide__
Accused-Appellee,
x------------------------------------------x
NOTICE OF APPEAL
COMES NOW the complain by the undersigned attorney and within the
reglementary period prescribed by the Rules of Court hereby files this notice of appeal
from the judgement of dismissal rendered by Mac Broke_ of RTC Branch 1
10:00 AM______, _August 11, 2015_____, Regional Trial Court Branch 1 City of
San Fernando Pampanga.
Atty.ABC Miserables_____________
(Counsel for the Accused)