Republic of the PhilippinesSixth Judicial Region

REGIONAL TRIAL COURT

Branch___Iloilo City
PEOPLE OF THE PHILIPPINES,
CRIMINAL CASE
NO._______P
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ROBBERY WITH HOMICIDE- versus TITO CRUZ AND VIC CRUZ,
Accused.x-----------------------------------------------x
PRE-TRIAL BRIEF OF THE PROSECUTIONT H E P E O P L E O F T H E P H I L I P 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 C i 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 . t h e i d e n t i t i e s o f t h o s e c h a r g e d i n t h e
i n f o r m a t i o n a n d t h a t o f t h e persons arraigned are one and the same;2. the identity of
Joey Cruz, the victim;3. the killing of the victim;4. the date and places of the commission of the
crime.
EVIDENCE FOR MARKINGS
1. Affidavit of the cashier Geraldine DemetriPurpose: to prove that she was on-duty when
the robbery took place and thatone of the accused pointed a gun at her, who eventually
declared hold-up whilethe other emptied the cash registers and took some grocery stuffs;2.
Affidavit of customer Bea RoblesPurpose: to prove that she was one of the customers at
the time the robberytook place and that she saw and identified the accused by their faces;3.
Affidavit of customer Paris MichaelsPurpose: to corroborate the testimonies of Geraldine
Demetri and Bea Robles;3. Autopsy Report of Joey Cruz issued by Iloilo Mission
HospitalPurpose: to prove the extent of the injury and the cause of death of the victim;4. Blotter
Report of Jaro Police Station (ICP-PP3)Purpose: to prove that the police authority received a
report that a robbery tookplace at Iloilo Supermart, located at Tabuk Suba, Jaro, Iloilo City.

5. Affidavit of Romeo V. BenamarcaPurpose: To prove that he personally heard a gun

shot from an abandoned ricem i l l a n d a c t u a l l y s a w t h e a c c u s e d h o l d i n g a
g u n a n d t h e d e a d b o d y o f t h e deceased which subsequently followed the arrest of the
accused.6. Paraffin test resultPurpose: To prove that accused became positive of gun powder
burns.7. Anatomical SketchP u r p o s e : To p r o v e w h i c h p a r t o f t h e v i c t i m s b o d y
w a s s h o t a n d t h e n a t u r e , extent and location of wound
.
8. Ballistics Test resultPurpose: To prove that the slug recovered from the victims body came
from thesame gun which was recovered from the possession of Tito Cruz.9. Fired Shell10. Three
live ammunitions11. .45 caliber pistol

ISSUES
1.Whether or not the accused committed the crime charged;2.Whether or not they
were guilty thereof.
WITNESSES
1. Geraldine Demetri to testify that a robbery took place;2 . B e a R o b l e s t o t e s t i f y t h a t
s h e w a s o n e o f t h e c u s t o m e r s o f t h e I l o i l o Supermart at the time the robbery took
place;3 . P a r i s M i c h a e l s t o t e s t i f y t h a t s h e w a s o n e o f t h e c u s t o m e r s o f
I l o i l o Supemart at the time the robbery took place.4. Romeo V. Benamarca to testify that he was
the police officer who wentto the scene of the crime and arrested the accused.5 . D r a . I s a b e l
C e n o n 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 examination of
J o e y C r u z a n d t o a t t e s t t o t h e v e 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.6.
Police Senior Inspector Anthony Villar to testify that he conducted the b a l l i s t i c s
e x a m i n a t i o n a n d t o a t t e s t t o t h e v e r a c i t y o f h i s f i n d i n g s i n t h e s a i d report.7.
Chemist Dionisia Paqui to testify that she conducted a paraffin test to the accused and
to attest to the veracity of her findings in the said report.
TRIALDATES
Specifically all Fridays of the month, with the regular appearance of the undersigned
city prosecutors before this Honorable Court.
RESPECTFULLY SUBMITTED.
Iloilo City, Iloilo, Philippines, July 4, 2008.
ILOILO CITY PROSECUTORS OFFICE
Ramon Q. Avancea Hall of JusticeBonifacio Drive,Iloilo City
By:
JOHN FRED C. HALLARES
Assistant City ProsecutorRoll No. 67890 / 5-2-07IBP. No. 667899 / 12-29-07MCLE ExemptPTR
Exempt
And
JASIE ANN MAGHOPOY
Assistant City ProsecutorRoll No. 67891 / 5-2-07IBP No. 667900 / 12-29-07MCLE ExemptPTR
Exempt
Copy furnished:
ATTY. KENETH P. TUPAS
Counsel for the DefenseRoom 200, New Valentine Bldg.Central Philippine UniversityLopez
Jaena St., Jaro, Iloilo CityReceived by:___________Date: ___________