Republic of the Philippines

Fourth Judicial Region

REGIONAL TRIAL COURT
Branch ___
Puerto Princesa City


PEOPLE OF THE PHILIPPINES, plaintiff, CRIMINAL CASE NO. _____
-versus- FOR:
RAMIR MANLAVI Y PARCON alias DUDAY, accused. MURDER
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PRE TRIAL BRIEF OF THE PROSECUTION
THE PEOPLE OF THE PHILIIPPINES, 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 proposed stipulation of facts:
1. That one Ramir Manlavi alias Duday, 19 years old, a resident of Purok Sandiwa, Brgy.
Tiniguiban,City of Puerto Princesa, is the accusedin this case;

2. That ZEUS ZENAROSA, deceased, 26 years old, and a resident of Bgy. Tiniguiban, Puerto Princesa
City is the victim of the crime of murder;

3. That the accused wilfully, intentionally and feloniously killed the victim by striking him with a
stone wrapped in a black shirt and hitting on his head which caused the latters death;

4. That the date, place and time of the killing, which was 31 October 2013 at about 8:20 in the
evening at Purok Sandiwa, Bgy. Tiniguiban, Puerto Princesa City.

EVIDENCE FOR MARKING

1. Supplemental Affidavit of Alcaleb de Jesue
Purpose: To prove that he was at the place where the crime was committed and saw that the
accused killed the victim.
2. Supplemental Affidavit of Roel Cadacio

Purpose: To prove that he was at the place where the crime was committed and saw that the
accused killed the victim.

3. Medicolegal Report issued by Dr. Raoul Dennis De Jesus

Purpose: That he examined the victim and to prove that the cause of death is Blunt Traumatic
Injury to the head.


ISSUE

1. Whether or not the accused is guilty of committing the crime;
2. Whether or not the victim death is caused by the stumbling or falling of the victim.

WITNESSESS
1. Alcaleb De Jesus to testify that he was present and accused Ramil Parcon alias Duday killed the
victim;

2. Roel Cadacio to testify that he was present and accused Ramil Parcon alias Duday killed the
victim;

3. Dr. De Jesus to testify that he examined the victim and that the death of the latter as due to the
Blunt Traumatic Injury to the head which is caused by the striking of the hard object in the
victims head.



TRIAL DATES

Specifically all Fridays of the month, with regular appearance of the undersigned City
Prosecutor before this Honorable Court.


RESPECTFULLY SUBMITTED
Puerto Princesa City, 11 October 2014



PROS. IRA DELA ROSA
PROS. HAZIELL PASCUA
PROS. DEVIEANN MAE LAMBAN
City Prosecutors
City of Puerto Princesa



Copy Furnished:

Malatag, Postre and Malatag Law Office
Room 100, Petal Building
Manalo St.,
Puerto Princesa City.