Republic of the Philippines

REGIONAL TRIAL COURT

11th Judicial Division
Branch 24
Hall of Justice
Koronadal City, South Cotabato

PEOPLE OF THE PHILIPPINES, CRIMINAL CASE NO.8531-24

Plaintiff, FOR:
Violation of Section 5 of Article 2 of
RA 9165
- versus -

ANTHONY REGONIEL DELOS SANTOS

And LETECIA DEQUILLO KONG,
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 trading, delivering and selling of shabu;
4. the date and places of the commission of the crime.
EVIDENCE FOR MARKINGS
1. Information as Exh. A
Purpose: to prove that a case has been duly filed with this court;
2. Joint Affidavit of Poseur Buyer/ Seizing/Arresting Officer as Exh B
Purpose: to prove that PO2 Serrano as the assigned poseur buyer was able to
close a transaction of buying shabu from the accused, and that the accused sold
and handed the illegal drugs to him with a consideration. That PO2 Serrano and
SPO1 Lanaza, the latter being the assigned arresting officer, upon arresting the
accused, recovered from the latter the same evidence presented in court. And
further, that they turned over the shabu seized to the crime laboratory for
examination. Lastly, that the police officers positively identified the accused;
3. Judicial Affidavit of Poseur buyer, PO2 Jerome Serrano as Exh C;
Purpose: to constitute his direct examination;
3. Chemistry Reports for the seized illegal drugs from accused Delos
Santos as Exh D
Purpose: to prove that the illegal drugs recovered from the accused and that he
sold to PO2 Serrano contained Methamphetamine Hydrochloride also known as
shabu;
4. Chain of Custody (from seizure to laboratory examination) of the illegal
drugs recovered from Accused Delos Santos as Exh E
Purpose: to prove the illegal drugs recovered from the accused were the same
items subjected to laboratory examination by the chemist;
5. Chain of Custody (from seizure to laboratory examination) of the illegal
drug recovered from Accused Dequillo as Exh F.
Purpose: to prove the illegal drug recovered from the accused was the same as
that subjected to laboratory examination by the chemist.
6. Photographs taken during the operation as Exh G
Purpose: To prove that the accused were duly arrested, and that the procedure
of the inventory, sealing, and labeling were properly observed.
7. Inventory Receipt of Seized Items as Exh H
Purpose: To prove that the police officers observed the procedure of Inventory
as prescribed in Section 21 of RA 9165, and that the items stated in the
document were the same items recovered from the accused.
8. Certification of PO2 Serrano pertaining to the marked money recovered
from the accused as Exh I
Purpose: To prove that the P1,000.00 bill marked money signed by the poseur
buyer prior to the operation was the same marked money recovered from the
accused upon arrest.
9. Chemistry Reports for the seized illegal drugs from accused Dequillo as
Exh J
Purpose: To prove that the illegal drug recovered from the accused contained
Methamphetamine Hydrochloride also known as shabu;
10. Judicial Affidavit of SPO1 Lanaza as Exh K
Purpose: To constitute as his direct examination.
11. Affidavit/Complaint of the Team Leader as Exh L
Purpose: To corroborate the testimony of PO2 Serrano and SPO1 Lanaza as to
the acts committed by the accused and the resulting arrest of the latter. To
testify on the proper handling and turnover of the seized illegal drugs from their
custody up to the crime laboratory for the examination.
12. Pre-operation Report as Exh M
13. Coordination Report as Exh N
14. Request for Qualitative Analysis for the seized illegal drugs from
accused Delos Santos as Exh O
Purpose: To prove that the arresting officer observed the initial procedure for the
conduct of the laboratory examination of the seized illegal drugs.
15. Request for Qualitative Analysis for the seized illegal drugs from
accused Dequillo as Exh P
Purpose: To prove that the arresting officer observed the initial procedure for the
conduct of the laboratory examination of the seized illegal drugs.
16. Indorsement to the City Prosecution Office as Exh Q
Purpose: To prove that the case was submitted for inquest and the corresponding
attachments to support the claim that the accused violated Sec 5 of RA 9165.
17. Inquest Resolution as Exh R
18. PNP Arrest and Booking Sheet of Delos Santos as Exh S
19. PNP Arrest and Booking Sheet of Dequillo as Exh T
20. Investigation Data Form as Exh U
21. Judicial Affidavit of PSI Honorio Ani as Exh V
Purpose: To corroborate the testimony of the witnesses on the chain of custody
of the seized illegal drugs and to certify the correctness of the conduct and
corresponding result of the laboratory examination of the same items.

ISSUES
1. Whether or not the accused committed the crime charged;
2. Whether or not they were guilty thereof.
WITNESSES
1. PO2 Jerome Serrano as Poseur Buyer of the Buy-Bust Operation;
2. SPO1 Arden Lanaza as the Arresting officer in the buy-bust operation;
3. PSI Alex Joe Orcajada as the team leader during the buy-bust
operation;
4. PSI Honorio Ani as the Forensic Chemist who examined the seized
illegal drugs
TRIAL DATES
Specifically all Saturdays of the month, with the regular appearance of the
undersigned city prosecutors before this Honorable Court.
RESPECTFULLY SUBMITTED.
Koronadal City, Philippines, October 25, 2012.

OFFICE OF THE CITY PROSECUTOR

Hall of Justice
Koronadal City

By:

SHIENA LOU B. AMODIA

 Assistant City Prosecutor
Roll No. 6989
IBP. No. 8881
MCLE V-0002306, August 9, 2012
PTR No 696968

And

KAY AVILES
Assistant City Prosecutor
Roll No. 67891
IBP No. 667900
MCLE Exempt
PTR Exempt
Copy furnished:

ATTY. JIMMY LUMINDAS

Counsel for the Defense
#69 Mansanitas St.,
General Santos City

Received by:___________
Date: ___________