Republic of the Philippines

REGIONAL TRIAL COURT

FOURTH JUDICIAL REGION
Br__, Pasay City

PEOPLE OF THE PHILIPPINES

- versus - CRIMINAL CASE NO. _____

For: Murder
RONALD OCAMPO
(Sitio Arellano, Barangay Menlo, Pasay
City),
Accused,
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PRE-TRIAL BRIEF OF THE PROSECUTION

COMES NOW, the Plaintiff, through the undersigned counsel, before this
Honorable Court, most respectfully submit this Pre-Trial Brief in compliance with
the Court’s order on February 7, 2019, containing the following:

1. The Prosecution is not willing to enter into an amicable settlement of the

case; There is likewise no plea bargaining agreement entered into;

2. Plaintiff admits the following facts:

2.1 The personal circumstance of the parties in the counter-affdiavit;

3. The Prosecution intends to present the following documents, in connection

with which the prosecution requests from the accused his admission of their
execution and due authenticity:
3.1 Exhibit A – Marriage contract of Eryhll Reena M. Guimpatan and
the victim Rolly Guimpatan.
3.2 Exhibit B – Affidavit of complainant Eryhll Reena M. Guimpatan
3.3 Exhibit C – Affidavit of witness Genevieve Ybañez
3.4 Exhibit D – Affidavit of witness PO1 Daniel Dominic Batula
3.5 Exhibit E – Affidavit of witness P/SUPT. Jesus Angelo Gomez, Jr.
MD.
3.6 Exhibit F – Death Certificate of the victim.
3.7 Exhibit G – Medical Autopsy Report of the victim.
3.8 Exhibit I – Knife obtained in the possession of the accused during
his arrest.
3.9 Exhibit J – Photo taken where the body of the victim was found.

4. Issue to be tried:
4.1 Whether or not the accused committed the crime charged against
him.

5. The prosecution intends to present the following witness:

5.1 Eryhll Reena M. Guimpatan, wife of the victim
5.2 Genevieve Ybañez, eye witness
5.3 PO1 Daniel Dominic Batula, arresting police inspector
5.4 P/SUPT. Jesus Angelo Gomez, Jr. MD., medico legal
 6. Plaintiff respectfully reserves the right to present other witnesses,
documents or evidences in addition to, or in substitution of, those
mentioned above and/or for purposes in addition to or in substitution of
those mentioned should a need thereof arises; propose other issues as
the exigencies of trial may demand; cite and invoke other laws and
jurisprudence that may be relevant in the course of the proceedings;
amend the pleadings, as may be warranted

WHEREFORE, prosecution prays that the foregoing be taken in

cognizance of.

City of Pasay, February 8, 2019

MARC ALFRED GARCIA

Assistant City Prosecutor

Copy furnished:

SENIN, Ruby
Counsel of the defense
Pasay City