Republic of the Philippines

Sixth Judicial Region

REGIONAL TRIAL COURT
Branch ___
Iloilo City

PEOPLE OF THE PHILIPPINES, CRIM.CASE NO. _______________

FOR: ROBBERY WITH HOMICIDE
-versus-

PETER AH CHU alias “Pikachu”,

JUAN PAOLO NAIGO alias “Cupcake”,
and JEYANO GIVES alias “Baby boy”
Accused.
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PRE-TRIAL BRIEF OF THE PROSECUTION

T H E P E O PL E O F T H E PH I L I P PI NE S , t h r o u g h t h e
u n d e r s i g n e d C i t y 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 one whose charged in the information and
that of the person arraigned are one and the same;
2. the identity of Margaret Bartolome, the victim
3. the date and places of the commission of the crime.
4. the robbery committed
5.the killing of the victim on the occasion of robbery
6. the existence of the CCTV footage in the entrance of the
subdivision.
7. the recovery of jewelry box containing a gold neck chain set with
three diamonds and four diamonds valued at Two Million Pesos
(P2,000,000.00)
8. the recovery of bladed weapon used.
9. the detached 3 glass jalousie blades.
10. car is owned and registered under the name of Pikachu used as get
away vehicle

EVIDENCE FOR MARKINGS

1. Police Report of Ricardo Dalisay- Investigator assigned at Jaro

City Police District
Purpose: to prove that the police authority received a report that a robbery
took place, the killing of the victim, Margaret in her residence situated at
Blk 1 Lot 1 Ledesco Village Jaro, Iloilo City and the condition/scenario of
the crime scene upon their arrival and during the investigation.
2. Affidavit of CCTV Operator/ House Guard Cristoff Taňada.
Purpose: to prove the existence and authenticate and attest to the
genuineness of the recorded video footage caught by the CCTV camera in
the entrance area of the subdivision and to testify that he received a call
from Nadia that she heard a loud scream and the presence of unidentified
persons in Bartoleme’s residence.
3. Affidavit of Casandra Mondragon.
Purpose: stand as witness in the commission of the crime specifically to
prove the robbery, the scenario and the killing of the victim.
3. Affidavit Nadia Daniella
Purpose: to testify that she heard a loud scream of the victim, the get away
vehicle and the escaped of the accused.
4.Affidavit of Michael Tejada- Roving Guard
Purpose: to corroborate with the testimony of the House Guard and he
check the house of the victim and there he saw Casandra crying for help and
the bloody body of Margaret in the floor.
5. Affidavit of Nicanor Tupas- Police Officer III
Purpose: to corroborate with the testimony of Ricardo Dalisay and to
testify that the accused were arrested during the hot pursuit and the recovery
of stolen jewelries
6. Affidavit of Doctor Jikko Balido on Autopsy Report of Margaret
issued by West City Memorial Hospital.
Purpose: to prove the extent of the injury and the cause of death of the
victim;
7. Sketch of the crime scene
Purpose: to the prove the visibility of the crime from the position of the star
witness , Casandra.
8Affidavit of Maxim Millano
Purpose: to prove that the finger prints found in the detached jealousy
blades matches with the finger prints of the accused.
9.Bladed Weapon
10. Jewelry box and the jewelries.
11. Pictures of the crime scene and other relevant evidence pertaining
to the commission of the crime.

ISSUES

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

2. Whether or not they were guilty thereof.
 WITNESSES

1. Ricardo Dalisay to testify that he was the police officer who responded to
the crime scene and conducted an investigation.
2.Cristoff Taňada to testify the existence of the CCTV video footage and its
content.
3. Casandra Mondragon, to testify that the killing of the victim was
committed by Peter Ah Chu alias “Pikachu”, Juan Paolo Naigo alias
“Cupcake” and Jeyano Gives alias “Baby boy”.
4. Nadia Daniella to testify that she saw the escaped and the get away
vehicle of the accused.
5. Michael Tejada to testify that he checked the house of the victim after the
report from the House Guard.
6. Nicanor Tupas to testify the arrest of the accused and recovery of the
stolen items.
6. Dr Jikko Balido to testify that he conducted the post mortem examination
of Margaret and to attest to the veracity of his findings in the autopsy report.
7.Maxim Millano to testify on the result of the finger print test.

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, Philippines, _____, 2019.

ILOILO CITY PROSECUTOR’S OFFICE

By:

ATTY. JERALDINE M. DALUPINES

Assistant City Prosecutor

And

PEDRO C. OILAB
City Prosecutor

Copy furnished:
ATTY. MART RONEL CATAYTAY
Counsel for the Defense

Received by:_______________
Date: _____________________