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LUCENA CITY
BRANCH___________
-versus- -for-
ROBBERY
Accused
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THE PEOPLE OF THE PHILIPPINES, through the undersigned City Prosecutor, before this
Honorable Court, most respectfully submit this Pre trial Brief
1. The identities of those charged in the information and that of the persons arraigned
are one and the same;
2. The identity of Maya, the victim;
3. The date, and place of the commission of the crime;
4. The robbery was committed by means of conspiracy;
5. The recovery of the 10 trays of jewelry allegedly owned by Maya, the victim;
6. The recovery of the walkie-talkies used by Atty.Sir Chief ,Jinggoy, and Juan;
7. Walkie-talkie of Emerson Calatrava which he surrendered voluntarily.
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EVIDENCE FOR MARKINGS
Purpose: To prove that the police authority received a report that a robbery took
place at the residence of Maya situated at Lucena City.
Purpose: To describe the scene of the crime the next day that it was discovered and
describe the conversation he intercepted in his walkie talkie.
Purpose: To prove that the recovered jewelries are of the same kind belonging to
the victim, Maya.
Purpose: To prove that the suspects are indeed the same persons caught in the
video footage at the scene of the crime
6. Walkie Talkies recovered from Sir Chief, Jinggoy, Juan and Joaquin
Purpose: To prove to the identity and conspiracy of Atty. Sir Chief, Joaquin, Jinggoy
and Juan in committing the crime
ISSUES
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WITNESSES
1.) Police Senior Inspector Rommel Alday - to testify that he had received a report of
robbery at the residence of Maya.
2.) CCTV Operator Ricardo Oabel to testify that the video footage was genuine and to
identify the suspects are the same persons caught on camera.
3.) Emerson Calatrava- to testify that he saw body of Maya the next day the crime was
committed and to testify to the truth of the conspiracy because he intercepted a signal
from his own walkie talkie the conversation of Atty. Sir Chief, Jinggoy, Juan and Joaquin
TRIAL DATES
Specifically all Mondays of the month, with regular appearance of the undersigned City
Prosecutors before this Honorable Court.
RESPECTFULLY SUBMITTED.
BY:
And
City Prosecutor
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Cc:
ATTY.DENNIS RAMIREZ
ATTY.EDELYN AYANGCO
ATTY.JOHN MARK SAPORNA
Counsels for the Defense
Received by:____________
Date: _________________
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