Republic of the Philippines

REGIONAL TRIAL COURT

11th Judicial Region
Branch

PEOPLE OF THE PHILIPPINES Criminal Case No. 27419 and 27420

Plaintiff,
FOR: VIOL. Of Sec. 5 and 11, ART.
-versus- II of R.A 9165 KNOWN AS THE
COMPREHENSIVEDANGEROUS
ARMAN CARIG ANTIPALA DRUGS ACT.
Accused.
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PRE-TRIAL GUIDE

COMES NOW, ACCUSED, assisted by the undersigned counsel and

unto this Honorable Court, respectfully submit this Pre-Trial Guide and
herein propose the following stipulations, THAT:

STIPULATIONS ADMITTE DENIED

D

1. The investigating officer has NO personal

knowledge of the buy-bust operation
conducted with the regard to this case.

2. The receiving officer and the forensic

chemical officer of the Davao del Norte
Police Provincial Crime Laboratory have NO
personal knowledge on how the accused was
arrested.

3. The receiving officer and the forensic

chemical officer of the Davao del Norte
Police Provincial Crime Laboratory have NO
personal knowledge on how and where the
specimen/s was/were marked by the
arresting and seizing officer.

4. The receiving officer and the forensic

chemical officer of the Davao del Norte
Police Provincial Crime Laboratory have NO
personal knowledge on who took the custody
of the specimen/s from the place of arrest
and /or seizure to the office of the team that
conducted the drug operation.

5. The receiving officer and the forensic

chemical officer of the Davao del Norte
Police Provincial Crime Laboratory have NO
personal knowledge on how the specimen/s
was/were transported from the place of
arrest or seizure to the office of the team

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 that conducted the drug operation.

6. The receiving officer and the forensic

chemical officer of the Davao del Norte
Police Provincial Crime Laboratory have NO
personal knowledge on how the specimen/s
was/were kept at the office of the team that
conducted the drug operation.

7. As to the witness of the defense, we will be presenting the following:

a. The Accused himself,

8. With respect to the documentary evidence, with reservationto mark

the Judicial Affidavit of the Accused as Exhibit 1.

WHEREFORE, premises considered, it is respectfully prayed of this

Honorable Court that the proposed stipulations be duly noted in the records
of the case.

RESPECTFULLY SUBMITTED.City of Tagum, Davao del Norte,

Philippines. October 4, 2021.

By:

PUBLIC ATTORNEY’S OFFICE

Regional Office XI
Tagum District Office
Counsel for the Accused

ROTHEA A. SIMON
Public Attorney II
Roll No. 67938
IBP No. 123889/Davao City
MCLE Compliance No. VI -0009812/April 14, 2022

Copy furnished:

Office of the City Prosecutor

Tagum City, Davao del Norte

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