Republic of the Philippines

Third Judicial Region

REGIONAL TRIAL COURT
Branch 20 Pasay City

PEOPLE OF THE PHILIPPINES,

Plaintiff,
CRIMINAL CASE no. 12345
FOR: PARRICIDE
-versus-

Hero L. Santos
Accused.

x-----------------------------------------------x

PRE-TRIAL BRIEF OF THE PROSECUTION

T H E P E O P LE O F T HE P HI LIP P I N E S , t h r o u g h t h e
u n d e r s i g n e d Ci t y Prosecutor, before this Honorable Court, most
respectfully submit this Pre-TrialBrief:

SUMMARY OF ADMITTED FACTS

AND PROPOSED STIPULATION OF FACTS

The following are the admitted facts:

1. The identity of the person charged in the
i n f o r m a t i o n a n d t h a t o f t h e person arraigned is one
and the same;

2. The identity of Gemma Santos, the victim;

3. Lawful arrest without warrant of the accused.

4. The killing of the victim was with intent by the accused.

5. The date and places of the commission of the crime.

6. The butterfly knife “balisong” used by the accused in

stabbing the victim.

7. That the accused Hero Santos is guilty thereof of the crime

Murder under Art. 246 of the Revised Penal Code.

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 EVIDENCE FOR MARKINGS

1. Marriage Certificate
Purpose: To prove that the private complainant is the lawful
husband of the deceased.

2. Death Certificate
Purpose: To prove the date, location and cause of death.

3. Birth Certificate
Purpose: To prove that the accused is the son of the deceased.

4. Affidavit of the Arresting Officer

Purpose: To prove that there was indeed commission of killing
of the deceased and lawful arrest without warrant of the
accused.

5. Affidavit of the Investigator on Case

Purpose: To prove that all documents to be presented were
based thru lawful investigation.

6. Photograph of the deceased

Purpose: To prove the identity of the victim Gemma Santos.

7. Pieces of Evidence “Balisong”

Purpose: To prove that the “balisong” was used as the deadly
weapon to consummate the said crime.

8. Serology/Forensic Examination
Purpose: To prove that the “balisong” used was matched in the
serology examination

9. Autopsy Result of Gemma Santos

Purpose: To prove the cause of death and the state of
health prior to death

10. Affidavit of Philip Santos, husband of the victim.

Purpose: to prove that he has personal knowledge in the
commission of the crime.

11. Affidavit of Dra. Maria Isadora Argiente

Purpose: to prove the authenticity of Autopsy Report;

12. Spot Report of Pasay Police Station

Purpose: To establish all evidence leading to the guilt of the
accused

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13. Photographs inside the house of Mr. and Mr. Santos
Purpose: to prove that the place of commission of the crime is
exactly the same with the address of the accused.

14. Finger prints result

Purpose: To prove that the result matches with finger prints
found in the “balisong”

15. Anatomical Sketch

P u r p o s e : To p r o ve wh i c h p a r t o f t h e vi c t i m’ s b o d y
wa s s t a b b e d a n d t h e n a t u r e , extent and location of
wound.

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 ISSUES

1. Whether or not the accused committed the crime

charged;
2. Whether or not the accused is guilty thereof.

WITNESSES

1 . P h i l i p S a n t o s – t h e h u s b a n d o f t h e vi c t i m a n d h a s
p e r s o n a l k n o wl e d g e o f t h e c r i m e c o m mi t t e d .

2 . P O 2 J a i me L . D i m a g i b a – A r r e s t i n g O f f i c e r , t o
t e s t i f y t h a t t he a c c u s e d wa s l a wf u l l y a r r e s t e d
wi t h o u t wa r r a n t

3 . S P O 2 Ri c k y Da l i s a y – Ca s e I n ve s t i g a t o r , t o t e s t i f y
t h e ve r a c i t y o f t h e p i e c e s o f e vi d e n c e a c q u i r e d
d u r i n g t h e c a s e i n ve s t i g a t i o n .

4. D r a . M a r i a I s a d o r a A r g i e n t e - t o t e s t i f y t h a t
s h e c o n d u c t e d t h e p o s t - m o r t e m e xa m i n a t i o n o f
G e m ma S a n t o s a n d t o a t t e s t t o t h e ve r a c i t y o f h e r
f i n d i n g s i n t h e autopsy report.

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 TRIAL DATE

Specifically all day of the month, with the regular

appearance of the undersigned city prosecutors before this
Honorable Court.

RESPECTFULLY SUBMITTED.
Pasay City, Philippines, January 3, 2018.

PASAY CITY PROSECUTOR’S OFFICE

Rodrigo Roa’s Hall of Justice

F.B. Harrison Drive, Pasay
City

By:

PAUL RYAN QUIOGUE

Assistant City Prosecutor
Roll No. 67890 / 5-2-07
IBP. No. 667899 / 12-29-07
MCLE Exempt
PTR Exempt

And

LIEZL BARQUILLA
Assistant City Prosecutor
Roll No. 67891 / 5-2-07
IBP No. 667900 / 12-29-07
MCLE Exempt
PTR Exempt

Copy furnished:
ATTY. JOY BALLOVAR
Counsel for the Defense
Room 200, New Valentine Bldg.
Central Philippine University
Lopez Jaena St., Jaro, Iloilo City

Received by:___________
Date: ___________

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