PP vs.

PILLADO

PO2 RYAN C SEVERINO
Purpose : We offer the testimony of witness __________________ for the following purposes:
1. To prove the fact that a valid search and seizure proceedings was conducted in the house
of the accused and as a result of the search prohibited drugs were recovered;
2. To prove the fact that he validly effected the arrest of the accused;
3. To identify the items recovered from the accused;
4. He will testify on the contents of his affidavit and to identify the same.
I. Preliminaries
1. Mr. Witness, what is your profession?
2. What is your rank as a member of the Philippine National Police?
3. How long have you been in the service as a police officer?
4. Where are you presently assigned, Mr. Witness?
5. In the month of _____________, were you already assigned at La Carlota City Police
Station?
II. Search Warrant
6. On ___________, were you on duty that day?
7. Can you recall whether during that day, you conducted a search and seizure proceedings?
8. Who is the subject of the search warrant?
9. Is she the same __________, who is the accused in this case?
10. What is the location? (_______________________)
11. The location you mentioned, is this the residence of the accused?
12. Was the search authorized by a search warrant?
13. Do you have with you a copy of the search warrant?

OFFER Search warrant as EXHIBIT ____
III. Conduct of the Search and Seizure
14. What time did you proceed to the said location?
15. Who were your companions?
16. Upon arriving at the location, what happened?
17. How do you know for sure that the house was the house of the accused?
18. Aside from your fellow police officers, who else were present?
19. After _______ introduced the search warrant to the accused, what happened next?
20. Was the accused alone or was she with somebody? Who are they?
21. What in particular is your task in the operation?
22. What happened during your search?
23. Can you describe to us in particular, how you were able to find those items?
24. Aside from these, was their anything that was recovered?
25. When you found the items what did you do next?
IV. Photographs and Physical Inventory
26. Who made the markings?
27. Who took the photographs?
28. After __________ photographed the recovered items, what happened next?
29. Did you see him placed the markings?
30. Can you recall what were the markings?
31. Who else were present when he placed the markings on the recovered items?
32. Mr. Witness, I am showing you.are these the same items you recovered from the house
of the accused?
33. Can you explain the markings on these items?
34. After the markings was done, what happened next?
V. Arrest of the accused
35. What happened next?
(Ruby Pillado was arrested, inform her of her constitutional rights)
36. What happened when you arrested her?
37. Were you able to identify the person you arrested?
38. Is she the same person who is the accused in this case?
39. Is she inside the courtroom?
40. Where is she?
41. Do you have any proper documentation that the search was consented to by the accused?

Offer Consent to Conduct Search as EXHIBIT ___

42. Do you have any proper documentation that the items you mentioned earlier were the
items that you recovered from the house of the accused?

Offer Receipt as EXHIBIT ___
VI. Recording and Booking at the Police Station
43. After you arrested her, what happened next?
(brought her to the police station)
44. While you brought the accused to the police station, what happened to the recovered
items? Who has their custody?
45. What happened at the police station?
46. Can you recall what time the recording in the police station was finished?
47. How about the recovered items? What happened to them?
(PO1 Losarito kept the recovered evidence in his locker. Brought the evidence to the
crime lab the following day 2:30 pm)
48. Do you recall having executed an affidavit in connection with this case?
49. I am showing to you an affidavit dated May 7, 2012, is this the affidavit you have
executed?
50. There is a signature above the name PO2 RYAN C SEVERINO, whos signature is this?
51. Where did you subscribe this affidavit?
52. There is a signature above the stamped name Victor B. Tanoso, whose signature is this?
53. Why do you know that this is his signature?

We would like to offer this Affidavit which was pre-marked as EXHIBIT A, signature
above the name PO2 Ryan C Severino as EXHIBIT A-1, and signature of the subscribing
officer as EXHIBIT A-2.