CRIMINAL PROCEDURE SCRIPT

Title: The People of the Philippines vs. Juan Dela Cruz

Part 1: Arraignment
[Scene: A courtroom in a Regional Trial Court (RTC). The judge, PROBINSYA JUDGE
MENDOZA, is seated on the bench. The prosecutor, ATTORNEY GARCIA, is at the
prosecution table, while the defense counsel, ATTORNEY REYES, is with the
defendant, JUAN DELA CRUZ, at the defense table.]
Judge Mendoza: [Bangs gavel]
The Court is now in session. The case of The People of the Philippines versus Juan
Dela Cruz for the crime of robbery with violence under Article 294 of the Revised Penal
Code. Mr. Dela Cruz, please stand.
Juan Dela Cruz: [Rises and stands beside his counsel]
Judge Mendoza: Mr. Dela Cruz, you are charged with the crime of robbery with
violence as alleged in the information filed against you. Before we proceed, let me
remind you that you have the right to enter a plea. The charges state that on or about
the 15th of December 2023, you unlawfully took money from the complainant, Mr.
Antonio Reyes, by means of intimidation and physical force.
Judge Mendoza: How do you plead to these charges, Mr. Dela Cruz?
Defense Counsel (Atty. Reyes): Your Honor, on behalf of my client, we enter a plea of
not guilty.
Prosecutor (Atty. Garcia): Your Honor, the prosecution is ready to proceed.
Judge Mendoza: Noted. Mr. Dela Cruz, you have entered a plea of not guilty. The
Court will now proceed to set your bail.
Prosecutor Garcia: Your Honor, we recommend that bail be set at ₱100,000 in
accordance with the seriousness of the offense.
Defense Counsel Reyes: Your Honor, we respectfully request that the Court lower the
bail, as my client has no prior criminal record and poses no flight risk.
Judge Mendoza: I will set the bail at ₱75,000. Mr. Dela Cruz, you will be released upon
posting this amount. The next hearing is scheduled for the pre-trial conference on
January 15, 2024, at 8:30 AM. This court is adjourned.
[Bangs gavel]
Court session ends.
Part 2: Pre-Trial Conference
Judge Mendoza: Court is now in session for the pre-trial conference in the case of The
People of the Philippines versus Juan Dela Cruz. Counsel for both parties, please state
your presence.
Prosecutor Garcia: Your Honor, the prosecution is present and ready to proceed.
Defense Counsel Reyes: Your Honor, the defense is present and ready to proceed.
Judge Mendoza: Very well. The purpose of today’s hearing is to discuss matters to
expedite the trial, including stipulations on facts, identification of witnesses, and any
motions to be heard.
Judge Mendoza: Let’s begin with the stipulation of facts. Are there any facts that both
parties can agree upon, Mr. Garcia?
Prosecutor Garcia: Your Honor, the prosecution and the defense have agreed that the
victim, Mr. Antonio Reyes, was indeed present at the XYZ Convenience Store on the
evening of December 15, 2023, and that he was in fact accosted by the accused, Mr.
Dela Cruz, during the incident. We also agree that the amount of money taken by the
accused was ₱15,000.
Defense Counsel Reyes: That is correct, Your Honor. However, we dispute the
element of violence and the claim that my client intentionally threatened or physically
harmed the victim.
Judge Mendoza: Noted. Let’s move on to the witnesses. Ms. Garcia, please state your
list of witnesses.
Prosecutor Garcia: The prosecution will present the following witnesses:
1. Antonio Reyes, the victim, to testify regarding the robbery.
2. Police Officer Aileen Santos, to testify on the arrest of the accused.
3. Forensic expert Dr. Jose Cruz, to confirm the injuries sustained by the victim.
Judge Mendoza: Noted. Atty. Reyes, do you have any objections to the witnesses?
Defense Counsel Reyes: The defense will present the following witnesses:
1. Rita Dela Cruz, the accused’s sister, to testify regarding his whereabouts at the
time the crime took place.
2. Maria Lopez, the accused’s neighbor, to testify to his good character.
Defense Counsel Reyes: Your Honor, we will reserve our objections during the trial but
will contest the injuries as being consistent with the alleged use of force in the robbery.
Judge Mendoza: Very well. Let us now address any motions. Ms. Garcia, do you have
any motions to be addressed at this time?
Prosecutor Garcia: None, Your Honor.
Defense Counsel Reyes: Yes, Your Honor, we move to exclude the forensic evidence
on the grounds that the examination of the victim’s injuries was done without a proper
medical certificate and may not be reliable.
Judge Mendoza: I will take that motion under advisement and rule on it during the trial.
Judge Mendoza: Now, as for the trial schedule, we will proceed to trial starting
February 10, 2024, at 9:00 AM. This court is adjourned.
[Bangs gavel]
Court session ends.

Part 3: Trial
Judge Mendoza: Court is now in session for the trial in the case of The People of the
Philippines vs. Juan Dela Cruz. Ms. Garcia, you may begin with your opening
statement.
Prosecutor Garcia: [Stands and addresses the court]
Your Honor, members of the jury, the case before you today involves a robbery
committed by the accused, Juan Dela Cruz, against the victim, Mr. Antonio Reyes. On
the evening of December 15, 2023, Mr. Reyes was minding his business at the XYZ
Convenience Store when Mr. Dela Cruz accosted him, threatened him with physical
violence, and forcibly took ₱15,000. The prosecution will present video evidence,
witness testimony, and forensic analysis to show that the accused is guilty beyond a
reasonable doubt of robbery with violence.
Judge Mendoza: Thank you, Ms. Garcia. Atty. Reyes, your opening statement?
Defense Counsel Reyes: [Stands and addresses the court]
Your Honor, ladies and gentlemen of the jury, the defense will show that while Mr. Dela
Cruz was indeed at the XYZ Convenience Store, he did not commit any robbery, nor did
he use any violence. The victim’s claim that Mr. Dela Cruz threatened him with harm is
an exaggeration, and we will demonstrate that no significant injury occurred. We ask
that you keep an open mind and carefully consider the evidence as presented.
Judge Mendoza: Thank you, Atty. Reyes. Ms. Garcia, you may call your first witness.
Prosecutor Garcia: The prosecution calls Antonio Reyes to the stand.
Antonio Reyes enters the witness stand and is sworn in.
Prosecutor Garcia: Mr. Reyes, can you please tell the Court what happened on
December 15, 2023?
Antonio Reyes: I was working the night shift at the XYZ Convenience Store. Around 10
PM, a man, Juan Dela Cruz, came in, and immediately, he demanded money from the
register. When I hesitated, he pulled out a knife and threatened me. I was scared, and
he shoved me aside, taking ₱15,000. I tried to stop him, but he pushed me violently out
of the way.
Prosecutor Garcia: Did you recognize this man?
Antonio Reyes: Yes, that man there, Juan Dela Cruz.
Prosecutor Garcia: Your Honor, the witness has identified the defendant. No further
questions.
Judge Mendoza:
Atty. Reyes, you may cross-examine the witness.
Defense Counsel Reyes: Mr. Reyes, are you certain about the identity of the person
who robbed you?
Antonio Reyes: Yes, I’m sure.
Defense Counsel Reyes: But there were no other witnesses, correct?
Antonio Reyes: That’s correct.
Defense Counsel Reyes: Thank you, no further questions.
Judge Mendoza: Thank you. Ms. Garcia, do you have another witness?
Prosecutor Garcia: Yes, Your Honor. The prosecution calls Police Officer Aileen
Santos.
Prosecutor Garcia: Good morning, Officer Santos. Can you please introduce yourself
to the Court and your position?
Police Officer Santos: Good morning, Your Honor. My name is Aileen Santos, and I
am a police officer assigned to the Barangay Police Station in San Pedro. I have
been with the police force for five years.
Prosecutor Garcia: Thank you, Officer Santos. Can you tell the Court what happened
on the night of December 15, 2023?
Police Officer Santos: Yes, Your Honor. On that night, I was part of the team that
responded to a robbery incident at XYZ Convenience Store. The victim, Antonio
Reyes, had called the police around 10:30 PM to report that he had been robbed by a
man who was still at the scene. We immediately proceeded to the store.
Prosecutor Garcia: What did you find when you arrived at the scene?
Police Officer Santos: When we arrived, Mr. Reyes was visibly shaken but was able to
provide a description of the suspect. He said the suspect was a man named Juan Dela
Cruz and that he had threatened him with a knife during the robbery. Mr. Reyes also
told us that the suspect had fled the scene on foot.
Prosecutor Garcia: And what did you do next?
Police Officer Santos: We immediately conducted a manhunt in the area. After about
15 minutes, we spotted a man matching the description given by the victim. He was
walking briskly down the street and appeared to be trying to avoid our patrol car. When
we approached him, we identified him as Juan Dela Cruz.
Prosecutor Garcia: Did you arrest him?
Police Officer Santos: Yes, Your Honor. Based on the victim’s description and the
circumstances, we arrested Juan Dela Cruz for robbery with violence. He was read
his Miranda rights and taken into custody. Upon searching him, we found a small
knife in his possession, which the victim later identified as the weapon used in the
robbery.
Prosecutor Garcia: So, based on your investigation, were you able to confirm that Mr.
Dela Cruz was indeed involved in the robbery?
Police Officer Santos: Yes, Your Honor. The victim identified Mr. Dela Cruz as the
perpetrator of the robbery, and we found the knife, which was consistent with the
weapon described by Mr. Reyes.
Prosecutor Garcia: Did you make any other findings or gather any additional evidence
during your investigation?
Police Officer Santos: Yes, Your Honor. We reviewed the surveillance footage from
the convenience store, which showed the defendant approaching Mr. Reyes,
demanding money, and then physically shoving him aside. The footage corroborated the
victim’s account of the incident.
Prosecutor Garcia: Thank you, Officer Santos. No further questions, Your Honor.
Defense Counsel Reyes: Good morning, Officer Santos. You mentioned that you
arrested Juan Dela Cruz on December 15, 2023. Is that correct?
Police Officer Santos: Yes, that is correct, Atty. Reyes.
Defense Counsel Reyes: You stated that the victim, Mr. Reyes, was able to describe
the suspect. Is that right?
Police Officer Santos: Yes, that’s correct.
Defense Counsel Reyes: Did Mr. Reyes give you a specific description of the suspect
immediately after the incident, or was there a delay before he identified Mr. Dela Cruz?
Police Officer Santos: The description was given to us shortly after the call was made,
but it was a general description—just that the suspect was a man with a knife.
Defense Counsel Reyes: So, there wasn’t an immediate identification of the defendant.
The victim only described the suspect based on general features, correct?
Police Officer Santos: That’s correct, Atty. Reyes. He described the suspect as a male,
about 5’7" with short hair and wearing a jacket.
Defense Counsel Reyes: And you, Officer Santos, only found Juan Dela Cruz walking
near the area, correct?
Police Officer Santos: Yes, Atty. Reyes, we found him walking a short distance from
the convenience store.
Defense Counsel Reyes: So, you stopped Mr. Dela Cruz simply because he fit the
general description, not because you had a positive identification of him by the victim at
that point, correct?
Police Officer Santos: That’s correct, Atty. Reyes. The victim had not directly identified
him at the time we apprehended him. But he matched the description provided.
Defense Counsel Reyes: And after arresting him, you searched him and found a knife.
Can you confirm that this knife was the same one described by the victim?
Police Officer Santos: Yes, the victim later identified the knife as the one the suspect
had used during the robbery.
Defense Counsel Reyes: But isn’t it possible that the knife was in Mr. Dela Cruz’s
possession for other reasons? Could it have been a knife for personal use, unrelated to
the alleged robbery?
Police Officer Santos: It’s possible, Atty. Reyes, but the victim was very clear that it
was the same knife used in the robbery.
Defense Counsel Reyes: No further questions, Your Honor.
Judge Mendoza: Thank you, Officer Santos. You may step down.
Prosecutor Garcia: Your Honor, I would like to ask Officer Santos a brief follow-up
question.
Judge Mendoza: Proceed, Ms. Garcia.
Prosecutor Garcia: Officer Santos, you mentioned that the victim identified the knife as
the one used in the robbery. Was the victim able to identify it immediately upon seeing
it?
Police Officer Santos: Yes, Your Honor. When we showed the victim the knife during
the investigation, he immediately confirmed that it was the same knife used to threaten
him during the robbery.
Prosecutor Garcia: Thank you. No further questions, Your Honor.
Judge Mendoza: Thank you, Officer Santos. You are excused.
[The court looks at both parties for any further motions or evidence.]
Prosecutor Garcia: Good morning, Dr. Cruz. Can you please introduce yourself to the
Court and your qualifications?
Dr. Cruz: Good morning, Your Honor. I am Dr. Jose Cruz, a licensed forensic
pathologist. I have been practicing in the field of forensic medicine for 15 years. I hold a
doctorate in medicine, and I am currently working with the Philippine National Police
(PNP) Crime Laboratory as a forensic expert. I specialize in examining physical
evidence, injuries, and weapons in relation to criminal cases.
Prosecutor Garcia: Thank you, Dr. Cruz. Are you familiar with this case?
Dr. Cruz: Yes, I am, Your Honor. I was called to examine the victim, Antonio Reyes,
following his report of being robbed and assaulted on December 15, 2023.
Prosecutor Garcia: Can you describe the injuries sustained by Mr. Reyes during the
robbery?
Dr. Cruz: Yes, Your Honor. Upon my examination of Mr. Reyes, I found several injuries
on his body. He had a contusion (a bruise) on his left forearm, which I believe was
caused by blunt force trauma. There was also a small laceration (a cut) on his right
cheek, which appeared to be consistent with a sharp object, likely a knife.
Prosecutor Garcia: Was this laceration caused by the weapon that was found with the
defendant?
Dr. Cruz: Based on my examination of the wound and the nature of the cut, I can
confidently say that the injury was consistent with a blade. The knife recovered from
Juan Dela Cruz during his arrest was a 4-inch blade, which would be capable of causing
such a wound.
Prosecutor Garcia: And was the injury to Mr. Reyes consistent with the victim’s
account of the robbery?
Dr. Cruz: Yes, Your Honor. Mr. Reyes reported that the suspect threatened him with a
knife, and the injury on his cheek aligns with that statement. Additionally, he mentioned
that he tried to defend himself, which may explain the bruise on his forearm.
Prosecutor Garcia: Thank you, Dr. Cruz. Now, did you also examine the weapon that
was recovered from the defendant?
Dr. Cruz Yes, Your Honor. Upon examining the knife found with the defendant, I noted
that it was a small, serrated kitchen knife, with a 4-inch blade. The blade was consistent
with the type of injury I observed on the victim’s cheek.
Prosecutor Garcia: Was there any other forensic evidence collected at the crime
scene?
Dr. Cruz: Yes, Your Honor. I was able to collect fingerprint samples from the counter
inside the store, where the victim claimed the suspect had placed the knife. We also
gathered blood samples from the scene, which were later tested. The blood on the
counter was found to be consistent with the victim’s DNA, confirming that the injury
occurred at the location described by Mr. Reyes.
Prosecutor Garcia: Thank you, Dr. Cruz. Based on your examination and analysis,
what is your professional opinion regarding the cause of the victim’s injuries and the
involvement of the weapon found with the defendant?
Dr. Cruz: Based on my examination of the victim’s injuries, the knife, and the physical
evidence, it is my professional opinion that the knife recovered from the defendant
was likely the weapon used to inflict the injury on Mr. Reyes’ cheek. The contusion on
the forearm also suggests that the victim attempted to defend himself, which supports
the account that the suspect used violence during the robbery.
Prosecutor Garcia: Thank you, Dr. Cruz. No further questions, Your Honor.
Defense Counsel Reyes: Good morning, Dr. Cruz. You mentioned that the knife found
with Mr. Dela Cruz was a 4-inch serrated kitchen knife. Is that correct?
Dr. Cruz: Yes, that is correct.
Defense Counsel Reyes: And based on your examination, you concluded that this
knife was the likely cause of the victim’s cheek injury?
Dr. Cruz: Yes, Your Honor. The wound on the victim’s cheek was consistent with the
type of blade found on the knife.
Defense Counsel Reyes: However, isn’t it possible that the injury could have been
caused by another knife, or even another object entirely? After all, there are many types
of knives, and injuries caused by blunt objects can sometimes resemble cuts, correct?
Dr. Cruz: While it is possible for blunt force trauma to cause similar injuries, the shape,
depth, and nature of the victim’s wound are consistent with a sharp object like a knife.
Based on the victim’s description, the knife found with the defendant fits the pattern of
the injury.
Defense Counsel Reyes: So, you are saying that the wound on the victim’s cheek was
definitively caused by the knife recovered from Mr. Dela Cruz?
Dr. Cruz: I cannot say with 100% certainty, Atty. Reyes, but based on the wound's
characteristics and the knife’s condition, I can say that the injury was highly consistent
with the use of that knife.
Defense Counsel Reyes: I see. Now, you mentioned that you found blood samples at
the scene. Were those blood samples tested for any signs of the defendant’s
involvement, or did you only test for the victim’s DNA?
Dr. Cruz: We primarily tested the blood found at the scene to confirm that it was from
the victim, Mr. Reyes. We did not test the blood for the defendant’s DNA because it was
not relevant to the injury.
Defense Counsel Reyes: So, there was no testing done to definitively exclude the
possibility that Juan Dela Cruz was not involved in the injury or the robbery?
Dr. Cruz: No, Atty. Reyes. We focused on the victim’s blood as it was found on the
counter, which aligned with his statement of where the injury occurred.
Defense Counsel Reyes: Thank you, Dr. Cruz. No further questions, Your Honor.
Judge Mendoza:
Thank you, Dr. Cruz. You may step down.
[Dr. Cruz steps down from the witness stand and returns to his seat.]
Prosecutor Garcia: Your Honor, I would like to briefly clarify one point. Dr. Cruz, you
mentioned that the blood found on the counter was consistent with the victim’s DNA.
Did you find any evidence to suggest that the blood on the counter belonged to the
defendant, Juan Dela Cruz?
Dr. Cruz: No, Your Honor. The blood found on the counter was confirmed to be the
victim’s blood. There was no blood from the defendant at the scene.
Prosecutor Garcia: Thank you, Dr. Cruz. No further questions, Your Honor.
Judge Mendoza: Thank you, Dr. Cruz. You are excused.
[The court looks at both parties for any further motions or evidence.]
Defense Counsel Reyes: Your Honor, the defense now calls Rita Dela Cruz, the sister
of the defendant, Juan Dela Cruz, to testify on his behalf
Defense Counsel Reyes: Good morning, Ms. Dela Cruz. Can you please state your full
name for the record?
Rita Dela Cruz: Good morning, Your Honor. My name is Rita Dela Cruz.
Defense Counsel Reyes: Thank you, Ms. Dela Cruz. How are you related to the
defendant, Juan Dela Cruz?
Rita Dela Cruz: He is my older brother.
Defense Counsel Reyes: Can you tell the Court where you were on the evening of
December 15, 2023, the date when the alleged robbery occurred at the XYZ
Convenience Store?
Rita Dela Cruz: Yes, Your Honor. On that evening, my brother, Juan Dela Cruz, was at
my house. We were at home together for the entire evening.
Defense Counsel Reyes: Can you confirm what time your brother arrived at your
house?
Rita Dela Cruz: He came over around 6:30 PM. We had dinner together, and we spent
the rest of the evening talking. We were at home the whole time.
Defense Counsel Reyes: Was there any point during that evening when your brother
left your house?
Rita Dela Cruz: No, Your Honor. He stayed with me until about 9:00 PM. He did not
leave the house at any time.
Defense Counsel Reyes: So, to clarify, Juan Dela Cruz was with you at your home
from 6:30 PM until 9:00 PM on December 15, 2023, and he was not at the XYZ
Convenience Store at the time the robbery occurred?
Rita Dela Cruz: That is correct, Your Honor. He was with me the whole time. I have no
reason to lie. He could not have been at the store.
Defense Counsel Reyes: Thank you, Ms. Dela Cruz. I have no further questions at this
time.
Judge Mendoza: Prosecutor Garcia, do you have any cross-examination for the
witness?
Prosecutor Garcia: Yes, Your Honor.
Prosecutor Garcia: Good morning, Ms. Dela Cruz. I just have a few questions. You
testified that your brother, Juan Dela Cruz, was at your house from 6:30 PM to 9:00 PM
on December 15, 2023, correct?
Rita Dela Cruz: Yes, that’s correct.
Prosecutor Garcia: But do you have any evidence, such as a witness or any other
proof, to confirm that he was indeed at your house that evening?
Rita Dela Cruz: Well, I am his sister, and I can swear that he was with me the whole
time. We were in the house together.
Prosecutor Garcia: So, it’s your word alone that confirms he was at your house? There
are no other witnesses to corroborate your testimony?
Rita Dela Cruz: I am the only one who can confirm it, Your Honor. But I swear he was
with me.
Prosecutor Garcia: I see. But no one else can confirm that your brother was with you,
correct?
Rita Dela Cruz: That’s correct. No one else was with us at the time. But he was home
with me.
Prosecutor Garcia: Thank you, Ms. Dela Cruz. No further questions, Your Honor.
Defense Counsel Reyes: No redirect, Your Honor.
Judge Mendoza: Thank you, Ms. Dela Cruz. You may step down.
Defense Counsel Reyes: Your Honor, the defense now calls Maria Lopez, a neighbor
and long-time acquaintance of the defendant, Juan Dela Cruz, to testify regarding his
character.
Defense Counsel Reyes: Good morning, Ms. Lopez. Can you please state your full
name for the record?
Maria Lopez: Good morning, Your Honor. My name is Maria Lopez.
Defense Counsel Reyes: Thank you, Ms. Lopez. How are you related to the
defendant, Juan Dela Cruz?
Maria Lopez: I am his neighbor. I have known Juan Dela Cruz for over 10 years. We
live in the same neighborhood.
Defense Counsel Reyes: Can you describe the defendant’s reputation in the
community? Has he ever been involved in any criminal activities or violent behavior?
Maria Lopez: No, Your Honor. Juan Dela Cruz is known to be a kind and hardworking
person. He is very well-respected in our community. He has never been involved in any
criminal activities or any violent incidents. In fact, he is known to help his neighbors
whenever they need assistance, especially with repairs or when someone is in trouble.
Defense Counsel Reyes: Has Juan Dela Cruz ever been known to have a temper or to
engage in aggressive behavior?
Maria Lopez: No, not at all. I have never seen him lose his temper or act aggressively.
He is a calm and peaceful person. If there is ever a problem, he tries to resolve it
peacefully. He is someone who would help people and never harm them.
Defense Counsel Reyes: Can you recall any specific examples of Juan Dela Cruz
being helpful or showing kindness to others?
Maria Lopez: Yes, Your Honor. Last year, during the typhoon season, Juan helped
several of our neighbors who had their homes damaged. He went around, helping to
repair roofs and clearing debris from the streets. He didn’t ask for anything in return—he
just wanted to help. He has always been that way, always thinking of others before
himself.
Defense Counsel Reyes: So, based on your personal experience and your knowledge
of him, would you say that Juan Dela Cruz is someone who would commit a violent
crime, such as the one he is accused of in this case?
Maria Lopez: No, Your Honor. I cannot believe that Juan would ever do something like
that. He is not that kind of person. He is peaceful, kind, and hardworking. There is no
way he would have done what he is being accused of.
Defense Counsel Reyes: Thank you, Ms. Lopez. I have no further questions at this
time.
Judge Mendoza: Prosecutor Garcia, do you have any cross-examination for the
witness?
Prosecutor Garcia: Yes, Your Honor.
Prosecutor Garcia: Good morning, Ms. Lopez. You testified that Juan Dela Cruz is
known to be a peaceful and hardworking person in the community, correct?
Maria Lopez: Yes, that is correct.
Prosecutor Garcia: But does that mean you have never heard of him having any
arguments or conflicts with anyone in the neighborhood?
Maria Lopez: No, Your Honor. I’ve never heard of anything serious. He has had
disagreements, like anyone else, but they were never violent or out of control. He
resolves things calmly.
Prosecutor Garcia: So, while you say he is a peaceful person, you cannot completely
rule out the possibility that he could have gotten involved in some form of conflict or
confrontation, correct?
Maria Lopez: Well, no one is perfect, Your Honor. But Juan is the kind of person who
always tries to avoid conflicts and never lets things escalate into violence. I know him
well, and I am sure he would never hurt anyone.
Prosecutor Garcia: Thank you, Ms. Lopez. No further questions, Your Honor.
Defense Counsel Reyes: No redirect, Your Honor.
Judge Mendoza: Thank you, Ms. Lopez. You may step down.
Judge Mendoza: We will now proceed with the presentation of evidence. Atty. Garcia,
please present the remaining pieces of evidence for the prosecution.
Prosecution's Presentation of Evidence
Prosecutor Garcia: Thank you, Your Honor. The prosecution would like to formally offer
into evidence the following items:
1. Exhibit A: The surveillance footage from the XYZ Convenience Store showing
the incident of the robbery, including the defendant, Juan Dela Cruz,
approaching the victim, Antonio Reyes, and threatening him with a knife.
 2. Exhibit B: The knife recovered from the defendant, Juan Dela Cruz, during his
arrest. This item was collected as evidence and is consistent with the weapon
used to injure the victim.
3. Exhibit C: The medical certificate from Dr. Jose Cruz, confirming the victim’s
injuries, including the laceration on the cheek and contusion on the forearm,
both of which were consistent with the victim’s account of the events.
4. Exhibit D: The DNA analysis report, confirming that the blood found on the
counter inside the store belongs to the victim, Antonio Reyes.
5. Exhibit E: The police report detailing the arrest of Juan Dela Cruz, including
his identification as the suspect in the robbery based on the victim’s description.
The prosecution respectfully requests that these items be admitted into evidence, as
they support the charges against the defendant.
Judge Mendoza: Does the defense have any objections to the admission of these
pieces of evidence?
Defense Counsel Reyes: Your Honor, the defense has no objections to the admission
of the surveillance footage or the medical certificate. However, we would like to object to
the DNA report on the grounds that it does not specifically rule out other possibilities
and does not link the blood found at the scene directly to the defendant. The knife
recovered from the defendant was not definitively identified as the weapon used in the
crime, as it is not possible to conclusively match it with the victim’s wound.
Judge Mendoza: Noted. I will admit the surveillance footage, the medical certificate,
and the police report into evidence. The DNA report and knife will be admitted with
reservations, given the defense's objections.
Defense's Presentation of Evidence
Defense Counsel Reyes: Your Honor, the defense would like to offer the following
pieces of evidence in favor of the defendant:
1. Exhibit F: The alibi testimony from Rita Dela Cruz, the defendant's sister, who
claims that Juan Dela Cruz was at her house during the time of the alleged
robbery. She will testify that he could not have been at the XYZ Convenience
Store.
2. Exhibit G: The character witness testimony from Raul Santos, a neighbor of
the defendant, who attests to his good character and peaceful nature, stating that
it is highly unlikely the defendant would have committed a violent act.
The defense requests that these pieces of evidence be admitted into the record.
Judge Mendoza: The evidence is noted. We will now proceed to the closing
statements. Atty. Garcia, please present your closing statement.
Prosecutor Garcia: [Rises and addresses the court]
Your Honor, members of the jury, this case is clear. On December 15, 2023, the victim,
Antonio Reyes, was the target of a violent robbery at the XYZ Convenience Store. The
defendant, Juan Dela Cruz, approached Mr. Reyes, demanded money, and used a knife
to threaten and injure him. The victim bravely identified the defendant, and the evidence
corroborates his testimony.
We have presented surveillance footage showing the defendant at the scene, as well as
the knife recovered from his possession, which was consistent with the injuries inflicted
on the victim. The DNA analysis confirmed that the blood at the scene belonged to the
victim, linking him to the crime. Furthermore, the forensic examination showed that the
injuries were consistent with the use of a sharp weapon, which was likely the knife
found with the defendant.
While the defense has presented an alibi, it is weak and unsupported by any
independent witnesses or credible evidence. There is no doubt in our minds that Juan
Dela Cruz is guilty of robbery with violence. We ask that you return a verdict of guilty as
charged.
Defense Counsel Reyes: [Stands and addresses the court]
Your Honor, members of the jury, we acknowledge that the victim, Antonio Reyes, was
injured and that the incident at the XYZ Convenience Store was a traumatic experience.
However, the prosecution has not proven the defendant's guilt beyond a reasonable
doubt.
The surveillance footage does not conclusively show the defendant committing the
robbery; it only shows him in the vicinity of the store. The DNA evidence, while it
identifies the victim’s blood at the scene, does not link the defendant directly to the
crime. We must remember that the prosecution has failed to establish beyond a
reasonable doubt that Juan Dela Cruz used the knife or was responsible for the victim’s
injuries.
Furthermore, the defendant has presented an alibi, supported by his sister, Rita Dela
Cruz, who will testify that he was at home at the time of the robbery. We ask that you
consider this testimony seriously.
Finally, the defendant has no criminal history, and his character is unblemished. It is
highly unlikely that someone of his character would suddenly commit a violent act.
We respectfully ask that you find Juan Dela Cruz not guilty of the charges. Thank you.
Judge Mendoza: Thank you, Atty. Garcia and Atty. Reyes, for your closing statements.
This case is now submitted for my consideration and decision.
As the trier of fact, it is my responsibility to assess all the evidence presented during the
trial, including the testimonies of the witnesses and the exhibits. I must carefully
consider the credibility and weight of the evidence presented by both the prosecution
and the defense.
As the judge, I must decide based on the evidence presented, and not on emotions or
sympathy. I must evaluate whether the prosecution has proven that the defendant
committed the crime of robbery with violence.
After reviewing all the evidence, I will decide whether the prosecution has successfully
proven the defendant’s guilt beyond a reasonable doubt. If I find that the evidence
presented by the prosecution has met this standard, I will find the defendant guilty. If,
however, I find that the evidence is insufficient or that there is reasonable doubt, I will
acquit the defendant.
I will now take the case under advisement, and I will render my decision in due course.
[Court is adjourned as Judge Mendoza takes the case under advisement.]
Judge Mendoza: After careful consideration of the evidence presented during the trial, I
am now ready to render my decision in the case of People v. Juan Dela Cruz.
This case involves the charge of robbery with violence under the Revised Penal Code.
The prosecution has alleged that the defendant, Juan Dela Cruz, robbed the victim,
Antonio Reyes, at the XYZ Convenience Store on December 15, 2023, and used a knife
to inflict injury on the victim during the robbery. The defendant has pleaded not guilty,
and the defense has argued that the defendant was not at the scene of the crime,
presenting an alibi to support this claim.
1. The victim, Antonio Reyes, testified that he was approached by the defendant
while inside the convenience store. He stated that the defendant demanded
money and threatened him with a knife. The victim was injured in the process,
suffering a laceration on his cheek and a contusion on his forearm. The victim
identified the defendant as the person who committed the robbery.
2. The testimony of Dr. Jose Cruz, the forensic expert, corroborated the victim’s
account. Dr. Cruz confirmed that the victim’s injuries were consistent with a sharp
object, such as the knife recovered from the defendant. The medical certificate
confirmed the injuries sustained by the victim, and DNA testing confirmed that the
blood found at the crime scene belonged to the victim, Antonio Reyes.
3. The prosecution presented surveillance footage from the convenience store,
which showed the defendant at the scene during the time the robbery occurred.
The knife recovered from the defendant during his arrest was consistent with the
injuries inflicted on the victim.
4. The defendant presented an alibi through his sister, Rita Dela Cruz, who testified
that the defendant was at her house during the time of the crime. However, this
alibi was not corroborated by any other witnesses or physical evidence, and it
 was not sufficient to raise a reasonable doubt about the defendant’s presence at
the scene.
The charge against the defendant is robbery with violence. Under the Revised Penal
Code, the elements of the crime of robbery with violence are as follows:
1. That there was a taking of property belonging to another, in this case, the victim’s
personal belongings, which was not disputed in this trial.
2. That the defendant used violence or intimidation in the commission of the
robbery. In this case, the victim’s testimony, coupled with the forensic evidence,
establishes that the victim was injured by the defendant during the robbery, with
the use of a knife.
3. That the act of robbery was done with force and violence, as evidenced by the
injury sustained by the victim and the weapon found in the defendant’s
possession.
Based on the evidence, I find that the prosecution has proven beyond a reasonable
doubt that Juan Dela Cruz committed robbery with violence. The victim’s testimony was
credible, and the forensic and physical evidence corroborates his account. The
defendant’s alibi was not convincing and did not create a reasonable doubt about his
involvement in the crime.
Therefore, after considering all the facts and evidence, I hereby find the defendant,
Juan Dela Cruz, guilty of robbery with violence as charged.
Under the Revised Penal Code, the penalty for robbery with violence is prison
mayor, which is a range of 6 years and 1 day to 12 years of imprisonment.
After considering the circumstances of the crime, including the use of violence and the
injury inflicted on the victim, I impose the sentence of 8 years of imprisonment.
Additionally, the defendant is ordered to pay the victim, Antonio Reyes, the amount of
P50,000 as moral damages.
This decision is final, subject to appeal by the defendant within the time prescribed by
law.
This Court is adjourned.
[Bangs gavel]