REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

FIRST JUDICIAL REGION
BRANCH 60
BAGUIO CITY

THE PEOPLE OF THE

PHILIPPINES,
Plaintiff, CRIM. CASE NO. 42789-R

-versus- For

ERIC GUIAGUI MADAMBA, ATTEMPTED ROBBERY WITH

Accused. FORCE UPON THINGS
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PRE-TRIAL BRIEF FOR THE

PROSECUTION

WITH ALL DUE RESPECT TO THE HONORABLE COURT.

The Prosecution submits this Pre-Trial Brief and manifests:

1. AS TO PLEA BARGAINING:

The Prosecution manifests that the only plea bargain it would enter into would be
for the Accused to plead guilty to the crime charged.

II. AS TO STIPULATION OF FACTS:

The Prosecution proposes for stipulation the following facts:

1. Identity of the accused

2. Jurisdiction of the court

III. AS TO DOCUMENTS TO BE MARKED IN EVIDENCE:

The Prosecution prays for the marking of the following documents as Exhibits:

1. Exhibit “A” - Sworn-Statement of James Diamas Ramirez Jr.

1.1 Exhibit “A-1” - Name and Signature of James Diamas Ramirez Jr.

2. Exhibit “B” - Joint Affidavit of Arrest

3. Exhibit “C to C-16”- Photographs

4. Exhibit “D to D-3” - Mug Shots of Accused

5. Exhibit “E” - Medico Legal Certificate of Accused

6. Exhibit “F” - Jailer’s Receipt of Suspect

7. Exhibit “G” - Sworn-Statement of Jeffrey Taberara Tabuzo

7.1 Exhibit “G-1” - Name and Signature of Jeffrey Taberara Tabuzo
 The Prosecution reserves the presentation and marking of other documentary
evidence.

IV. NAMES OF WITNESSES:

The Prosecution will present the following witnesses:

1. James Diamas Ramirez Jr. – No. 247 Victoria Village, Baguio City
2. PSSg Jerry S. Dawan – BCPO Station 9
3. PCpl Rogdan G. Tabdi – BCPO Station 9
4. Jeffrey Taberara Tabuzo – No. 245 Purok 1 Victoria Village, Baguio City

The Prosecution prays for at least four (4) dates for the witnesses, the dates to be
fixed in conformity with the Court’s Calendar.

V. STATEMENT OF THE ISSUE:

The Prosecution submits that the issued to be resolved are: (a) whether the
Accused are guilty of the crime charged, and (b) whether the state is entitled to an award
for civil damages.

VI. AS TO OTHER MATTERS THAT COULD EXPEDITE THE

CASE

These matters may be considered during the course of the trial.

RESPECTFULLY SUBMITTED.

Baguio City, Philippines, October 2, 2019.

PHILIP RANDOLF F. KIAT-ONG

Associate City Prosecutor
Roll No. 43208/IBP Lifetime No. 05249
MCLE Compliance VI-0001525