Republic of the Philippines

11th Judicial Region

MUNICIPAL TRIAL COURT IN CITIES
Branch 9
Davao City

PEOPLE OF THE PHILIPPINES,

Plaintiff,
CRIMINAL CASE NO. XXXX
FOR: HOMICIDE
- versus

Reuben Rayos Alias Boy Kakak

Accused.
x------------------------------------------x

PRE-TRIAL BRIEF FOR THE PROSECUTION

THE PEOPLE OF THE PHILIPPINES, through the undersigned

private prosecutors under the direct control and supervision of the public
prosecutor, before this Honorable Court, most respectfully submits this Pre-
Trial Brief to wit:

SUMMARY OF ADMITTED FACTS AND

PROPOSED STIPULATION OF FACTS

1. The identity of the one charged in the information and that of the
person arraigned is one and the same;

2. The identity of Junie Jung, the victim;

3. The killing of the victim;

4. Thant the victim was one of the customer in Davao Highland

restaurant;

5. That the accused was the waiter in Highland restaurant and was the
one who served the order of the accused.

6. That the Victim shouted Pataka lang ka ug served, dili man kani
akong giorder the accused when he served the wrong order.

7. That the victim was with Marco Polongco, the victims business
partner, when the crime was committed.

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8. The date and place of the commission of the crime which was July 5,
2014, at 8:00 in the evening and at Davao highland restaurant, Davao
City.

9. SPO4 Charmi Jobelle Napalit is the police officer who arrested the
accused. And that she is assigned in San Pedro, Davao Police Station.

10.Dra. Sheng Batitao is a pathologist doctor who conducted the post-

morterm examination.

EVIDENCES FOR MARKING

1. Exhibit 1: Autopsy Report of Dra. Sheng Batitao issued by Davao

Medical Hospital

Purpose: To prove the extent of injury and the cause of death of the
victim;

2. Exhibit 2: Blotter Report of Davao Police Station (ICP-PP5)

Purpose: To prove that the police authority received a report that the
accused, acting by himself, did then and there, willfully, unlawfully
and feloniously, stab one Junie Jung, with the use of a double bladed
fan knife, on July 5, 2014, Davao City.

3. Exhibit 3: Anatomical sketch

Purpose: To prove which part of the victims body was stab and the
nature, extent and location of the wound.

4. Exhibit 4: diamond-studded, black handled, double bladed fan knife

Purpose: To prove that it was the material use to commit the crime.

I S S U E S:
I. Whether or not the accused committed the crime charged;
II. Whether or not he is guilty thereof

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 WITNESSES:

1. Marco Polongco to testify that he was with the victim when the crime
of homicide took place;
2. SPO4 Charmi Jobelle Napalit to testify that he was the police officer
who went to the scene of the crime and arrested the accused.
3. Dra. Sheng Batitao to testify that she conducted the post mortem
examination of Marc Alquiza and to attest the veracity of his findings
in the said report.

TRIAL DATES:
Specifically all Saturdays of the month, with the regular appearance of the
undersigned private prosecutors before this Honorable Court.

MOST RESPECTFULLY SUBMITTED this 24 September 2016

in City, Philippines.

DAVAO CITY PROSECUTORS OFFICE

HALL OF JUSTICE
4F, BEP Bldg., Davao City

By:

ATTY. MELANIE JOY Y. CHUA

Assistant City Prosecutor
Roll No. 78260
IBP No. 855987, January 13, 2016 Davao, Philippines
PTR No. 4569016, January 13, 2016 Davao City
MCLE Exemption No. IV-000888
E-mail address: antfirm_law@yahoo.com

And

ATTY. MADONA PASCUAL

Assistant City Prosecutor

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 Roll No. 25026
IBP No. 200987, January 13, 2016 Davao City, Philippines
PTR No. 3929016, January 13, 2016 Davao City
MCLE Exemption No. IV-000544
E-mail address: antfirm_law@yahoo.com

CC:
ATTY. Lee Ivy Acevedo
Counsel for the Defense
Unit 168, Babar Bldg.
Buhangin, City

ATTY. SARAH PACLIBAR

Clerk of Court
Branch 9
Municipal Trial Court in Cities
City