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 identities of those charged in the information and that of the persons arraigned are one and the same; 2. the identity of Meg Anthony M. Miralles, the victim; 3. that the accused raped the victim; 4. the date and places of the commission of the crime. EVIDENCE FOR MARKINGS 1. Affidavit of the victim Meg Anthony M. Miralles Purpose: to prove that she was on-duty when the robbery took place and that one of the accused pointed a gun at her, who eventually declared hold-up while the other emptied the cash registers and took some grocery stuffs; 2. Medico-Legal prepared by Dr. Meneses, Lana 3. Police report filed by the victim on February16, 2017 ISSUES 1. Whether or not the accused committed the crime charged; 2. Whether or not he was guilty thereof. WITNESSES 1. Meg Anthony M. Miralles to testify that he was raped by the accused; 2. Dr. Meneses, Lana to testify on the medico-legal report; 3. SPO1 Tejana, Ritchie to testify that the victim reported the incident. TRIAL DATES Specifically all Fridays of the month, with the regular appearance of the undersigned city prosecutors before this Honorable Court. RESPECTFULLY SUBMITTED. Iloilo City, Iloilo, Philippines, March 9, 2017.
ILOILO CITY PROSECUTOR’S OFFICE
Ramon Q. Avanceña Hall of Justice Bonifacio Drive,Iloilo City
By:
JOHN FRED C. HALLARES
Assistant City Prosecutor Roll No. 67890 / 5-2-07 IBP. No. 667899 / 12-29-07 MCLE Exempt PTR Exempt
And
JASIE ANN MAGHOPOY
Assistant City Prosecutor Roll No. 67891 / 5-2-07 IBP No. 667900 / 12-29-07 MCLE Exempt PTR Exempt Copy furnished:
ATTY. KENETH P. TUPAS
Counsel for the Defense Room 200, New Valentine Bldg. Central Philippine University Lopez Jaena St., Jaro, Iloilo City