Republic of the Philippines

National Capital Judicial Region

Regional Trial Court
Branch 1, Pasay City

PEOPLE OF THE PHILIPPINES

Plaintiff,

- versus - Criminal Case No.: 001-2015

FOR: Kidnapping with Murder
ALVAN OLIVEROS
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 January 7, 2015, 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 Roselyn Barrientos and the victim
Sadam Prudenciano.
3.2 Exhibit B – Affidavit of complainant Roselyn Barrientos
3.3 Exhibit C – Affidavit of witness Kevin Dela Cruz
3.2.1 Exhibit B.1 – the name and signature of Kevin Dela Cruz.
3.3 Exhibit D – Affidavit of witness Maureen Patajo
3.3.1 Exhibit C.1 – the name and signature of Maureen Patajo.
3.4 Exhibit E – Death Certificate of the victim.
3.5 Exhibit F – Medical Autopsy Report of the victim.
3.6 Exhibit G – PostMortem Dental Record of the victim.
3.7 Exhibit H – .45Caliber Gun obtained in the possession of the accused
during his arrest.
3.8 Exhibit I – One Million Pesos ransom money 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;
4.2 Whether or not the accused was validly arrested;

5. The prosecution intends to present the following witness:

5.1 Rosely Barrientos, wife of the victim
5.2 Kevin Dela Cruz, eye witness
5.3 Maureen Patajo, eye witness
5.4 Jal Disomimba, arresting police inspector
5.5 Dr. Judy Anne Yulo, medico legal
 WHEREFORE, prosecution prays that the foregoing be taken in cognizance of.

City of Pasay, February 8, 2015

Edward Confiado Santiago

Assistant City Prosecutor

Copy furnished:

Rich Almario
Counsel of the defense
123 Ayala Ave., Makati City