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Regional Trial Court: Summary of Admitted Facts and Proposed Stipulation of Facts

This document is a pre-trial brief submitted by the prosecution in a criminal case against Henry Chao. It summarizes the admitted facts, including the identity of the accused and victim, the court's jurisdiction, and the authenticity of documents. It also lists the proposed evidence, including affidavits from the victim, arresting officer, and witness, and an autopsy report. The brief identifies the main issues as whether the accused committed the crime and was guilty. It proposes witness testimony from the victim, arresting officer, and witness. Finally, it schedules future trial dates.

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Ella Mae Buhisan
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128 views3 pages

Regional Trial Court: Summary of Admitted Facts and Proposed Stipulation of Facts

This document is a pre-trial brief submitted by the prosecution in a criminal case against Henry Chao. It summarizes the admitted facts, including the identity of the accused and victim, the court's jurisdiction, and the authenticity of documents. It also lists the proposed evidence, including affidavits from the victim, arresting officer, and witness, and an autopsy report. The brief identifies the main issues as whether the accused committed the crime and was guilty. It proposes witness testimony from the victim, arresting officer, and witness. Finally, it schedules future trial dates.

Uploaded by

Ella Mae Buhisan
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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Republic of the Philippines

REGIONAL TRIAL COURT


Fourth Judicial Region Branch
Cagayan de Oro City

PEOPLE OF THE PHILIPPINES, CRIMINAL CASE NO. 1234567


Plaintiff,
FOR:
Violation of Anti-Bouncing
Check law
- versus -

HENRY CHAO,
Accused.
x-----------------------------------------------x

PRE-TRIAL BRIEF OF THE PROSECUTION

THE PEOPLE OF THE PHILIPPINES, through the undersigned City


Prosecutor, before this Honorable Court, most respectfully submit this
Pre-Trial Brief:

SUMMARY OF ADMITTED FACTS AND PROPOSED STIPULATION OF


FACTS

The following are the admitted facts:


1. The identity of the accused EDUARDO LANKIN in the information
and that of the person arraigned is one and the same;
2. The identity of TED MAGNO, the victim;
3. The Court’s territorial jurisdiction relative to the offense charged;
4. The cause of death of the victim;
5. The date and place of the commission of the crime;
6. The genuineness and due execution of the documents.
EVIDENCE FOR MARKINGS

1. Affidavit of the TED MICHAEL MAGNO

Purpose: to prove the commission of the crime by the accused


against the victim;

2. Affidavit of the PO1 ARVIE CHRISTOPHER SADILI

Purpose: to prove the date, place and other circumstances of the


commission of the crime;

3. Affidavit of customer ROSANNA MARIE MERGAL

Purpose: to corroborate the testimony of TED MICHAEL MAGNO


and PO1 ARVIE CHRISTOPHER SADILI;

4. Autopsy Report of EDGAR LANKIN issued by PAGAMUTANG


PANGMASA NG LAGUNA

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

ISSUES

1. Whether or not the accused committed the crime charged;


2. Whether or not they were guilty thereof.

WITNESSES

1. TED MICHAEL MAGNO to testify that the crime took place;


2. PO1 ARVIE CHRISTOPHER SADILI to testify that he was the officer
on duty patrolling in the vicinity of the crime scene during its
commission;
3. ROSSANA MARIE MERGAL to testify that she was at the crime scene
during its commission.
TRIAL DATES

Specifically all Fridays of the month, with the regular appearance


of the undersigned city prosecutor before this Honorable Court.

RESPECTFULLY SUBMITTED.
Calamba City, Laguna, Philippines, September 20, 2014.

CALAMBA CITY PROSECUTOR’S OFFICE


Ramon Q. Avanceña Hall of Justice
Bonifacio Drive, Calamba City

By:

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

Copy furnished:

ATTY. NESLEY CRUZ


Counsel for the Defense
Room 200, New Valentine Bldg.
Central Perpetual University
Lopez Jaena St., Rizal, Calamba City

Received by:___________
Date: ___________

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