Republic of the Philippines

REGIONAL TRIAL COURT

7
th
Judicial Region
Branch 19
Cebu, City



PEOPLE OF THE PHILIPPINES, CRIMINAL CASE NO. _____
Plaintiff, FOR: MURDER

-versus-

EDMUND G. FERNANDEZ
Accused.

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PRE-TRIAL BRIEF OF THE PROSECUTION


THE PEOPLE OF THE PHILIPPINES, t hr ough t he under s i gned Ci t y
Prosecutor, before this Honorable Court, most respectfully submit this Pre-Trial Brief:

SUMMARY OF ADMI TTED FACTS
AND PROPOSED STI PULATI ON OF FACTS

The following are the facts:

1. the identity of the accused charged in the information and that of the person arraigned are one and
the same;

2. the identity of Dennis Beltran the victim;

3. the killing of the victim;

4. the date and places of the commission of the crime;

5. the name of the wife of the victim;

6. the jurisdiction of the Court.


EVI DENCE FOR MARKI NGS

1. Affidavit of the witness Marilou Suarez
Purpose: to prove that she was present at the time of murder which took place
at One Mango Ave., Gen. Maxilom, Cebu City;

2. Affidavit of the Arresting Officer Glen Fortunado
Purpose: to prove that the accused was arrested by him after the accused was
bumped by a vehicle after fleeing from the crime scene;

3. Affidavit of the Wife, Mrs. Mehoney Ratilla
Purpose: to determine the extent of damages claimed against the accused-murderer;

4. Autopsy Report of Dennis Beltran issued by the PNP Medico Legal Dr. Caroline
Cumajig
Purpose: to prove the extent of the injury and the cause of death of the victim;

5. Anatomical Sketch
Pur pos e: To pr ove whi ch par t of t he vi ct i m s body was s hot and t he
nat ur e, extent and location of wound;

6. Paraffin test result
Purpose: To prove that accused became positive of gun powder burns.

7. Gun Powder Residue Test
Purpose: To determine whether the recovered firearm has been discharged.

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 Edmund G. Fernandez.

9. Firearms Verification Result
Purpose: To prove that the firearms recovered from the possession of the accused is an
unlicensed firearm.

10. Fired Shells

11. 4 live ammunitions

12. .45 caliber pistol

I S S U E S

1. Whether or not the accused committed the crime charged;

2. Whether or not he is guilty thereof.

W I T N E S S E S

1. Marilou Suarez to testify that she personally witness the shooting at One Mango Ave.,
Gen. Maxilom, Cebu City;

2. Glen Furtonado, arresting officer;

3. Mehoney Ratilla, the wife of the victim;

4. Medico Legal Dr. Caroline Cumajig, expert witness to testify the veracity of the autopsy
report;