Q: You made mention during your direct examination that you have been subjected to a

random drug test as a requirement for your continuous employment in Alta Business
Solution, am I correct?
A:

Q: How often are these random drug tests conducted?

A:

Q: You made mention as well that you had been employed in Alta Business Solution for
three years and five months, am I correct?
A:

Q: From the commencement of your employment in Alta Business Solution, how many
times have you been subjected of a random drug test?
A:

Q: Since you had been subjected to a total of ___ random drug tests, why did you only
present your Drug Test Laboratory Result dated 5 January 2017?
A:

Q: Are you still employed in Alta Business Solution?

A:

Q: Have you been subjected to random drug tests after the drug test you had last 5
January 2017?
A:

Q: If yes, why did you not present those other drug test results? / If no, you made
mention that from a span of three years and five months, you were subjected to a total
of ____ random drug tests, why were you not subjected to further random drug tests? /
If no because you are detained, why did you not ask for a drug test during your
detention?
A:

Q: Moreover, Mr. Witness, in your direct examination, you made mention that you
supposedly obtained a loan from a certain Mrs. Maria Clara Burgos for an amount of
P200,000.00, am I correct?
A:

Q: And you likewise stated in your direct examination that you became familiar with PO1
Burgos, the poseur buyer in this case, because he is your neighbor and that his wife
has a lending business, is that also correct?
A:

Q: When you obtained that supposed loan, Mr. Witness, who were you actually
transacting with?
A:

Q: Have you ever met PO1 Burgos during the period when you supposedly contracted
this loan from Mrs. Burgos?
A:

Q: After you obtained the loan from Mrs. Burgos until you defaulted from your payment
of the monthly installments, have you dealt with PO1 Burgos personally?
A:

Q: How about after you defaulted from your payment of the supposed loan, have you
dealt with PO1 Burgos personally?
A:

Q: Speaking of that supposed loan, can you tell this Court when you allegedly obtained
the same, Mr. Witness?
A:

Q: Why did you obtain that loan in the first place?

A:

Q: How many monthly installments were you able to pay from that supposed loan?
A:

Q: Why did you renege from your installment payment of that loan, Mr. Witness?
A:

Q: You made mention in your direct that PO1 Burgos supposedly began sending you
text messages since you first defaulted on your payment, am I correct?
A:

Q: When was the first time sent you a text message?

A:

Q: How did you know that it was PO1 Burgos who sent you those text messages?
A:

Q: Did you verify the identity of the person who sent you those test messages?
A:

Q: By what means?
A:

Q: Likewise, Mr. Witness, you identified during your direct examination a Certification
issued by SMART Telecommunications under the no. 09198888888, previously marked
as "D-3," am I correct?
A:

Q: Did you obtain a similar Certification with regard the mobile number with whom you
had the text exchange with?
A:

Q: If yes, where is it then? / If no, why not?

A:

Q: Do you have any proof that the number you had this text message exchange with if
that PO1 Burgos?
A:

Q: Did you also try calling the number from which you have been receiving those text
messages from?
A:

Q: Did you tell Mrs. Burgos about the text messages that her husband supposedly had
been sending you?
A:

Q: If yes, what did she say about it? / If no, why did you not do so?
A:

Q: How often do you receive these messages?

A:

Q: Did you respond to those messages?

A:

Q: From the time that you first defaulted from your monthly installments until January
10, 2017, how many times did you receive those text messages?
A:

Q: When you failed to pay after the fifth installment, did you communicate with Mrs.
Burgos, the person from whom you contracted the loan, regarding the same?
A:

Q: Since you answered in the affirmative, why did Mr. Burgos’ supposed text messages
convinced you to meet--not with Mrs. Burgos, who was the person to whom you
contracted the loan from--but with her husband, whom you had met for only ____ times
during the period of the loan? / Since your answer was in the negative, why didn’t you
communicate with Mrs. Burgos, the person from you obtained the loan, and instead
heeded the supposed text messages of P01 Burgos?
A:
Q: If you are really genuine in negotiating a settlement with your supposed loan to Mrs.
Burgos , why did it take you until January 10, 2017, which is more than six months from
the time you first defaulted from your monthly installments, to finally meet with PO1
Burgos?
A:

Q: And since you mentioned in your direct examination that it was you who pleaded for
an extension to pay due to the hospital expenses for the chemotherapy of your son, why
did you have to wait for PO1 Burgos, and not Mrs. Burgos, to meet with you regarding
the settlement of the your supposed loan?
A:

Q: Up until present, can you tell this Court if you had already paid that supposed loaned
amount in full?
A:

Q: In your direct examination, you mentioned, Mr. Witness, that you agreed to meet
PO1 Burgos at 7/11 in Brgy Concepcion in Mabalacat, is that correct?
A:

Q: Also in your direct examination, you likewise mentioned that PO1 Burgos was your
neighbor, right?
A:

Q: Why, then, did you agree to meet him in 7/11, Brgy. Concepcion, when his house
was merely 5 meters away from yours?
A:

Q: You mentioned, as well in your direct that you agreed to meet PO1 Burgos because
you, and I quote, “respected him as a police officer and he is my neighbor, and I
honestly thought that it would be safe for me to meet him at 7/11 especially because it is
a public place and we would meet at noon.” Why did you specifically need to state that it
was a public place, of all the probable descriptions that you may use?
A:

Q: Where were you, before you received that supposed text message asking you to
meet PO1 Burgos at 7/11 St.?
A:

Q: Would you know how far was _________ from 7/11 St.?
A:

Q: How long did it take for you from ______ to 7/11 St.?
A:
Q: Mr. Witness, I am showing to you the Transcript of Stenographic Notes of the direct
examination of PO1 Jopat Dela Rosa, the arresting officer, last 8 November 2017, at the
time when you were likewise present in this Court for identification. I refer you to Page
5, can you please read this part aloud for the Court?
A: “Q: You mentioned that you were headed to 7/11 St., Brgy. Concepcion. How far is
that from the police station? A: About 12 to 15 minutes by car.”

Q: In the same Transcript of Stenographic Notes, on Page 15, can you please read this
part aloud for the benefit of the Court?
A: “Q: How long did it take for you to arrive in your police station? A: Around fifteen
minutes.”

Q: Now, I am showing to you the Transcript of Stenographic Notes of the direct

examination of PO1 Padre Burgos, the poseur buyer, last 8 November 2017, at the time
when you were likewise present in this Court for identification. I refer you to Page 5, can
you please read this part aloud for the Court?
A: “Q: How far is Barangay Concepcion from the police station? A: About 15 minutes by
car.”

Q: In the same Transcript of Stenographic Notes, on Page 12, can you please read this
part aloud for the benefit of the Court?
A: “Q: How long did it take for you to drive from the place of arrest to your police
station? A: About fifteen minutes.”

Q: You also said in your direct that you arrived early so you went inside 7/11 to wait for
PO1 Burgos, am I correct?
A:

Q: You also mentioned that you bought some food and cigarette while waiting for PO1
Burgos, correct?
A:

Q: Did you inform the number which had been texting and calling you that you already
arrived at your meeting place?
A:

Q: If yes, can you please show to this Court where that text message was in the text
exchange that you identified in this Court earlier, which is previously marked as Exhibit
"D"? / If no, why did you not do so?
A:

Q: Mr. Witness, in your direct examination, you mentioned you were buying food, and
then the next thing you testified was as to your arrest. For the guidane of the Court, can
you tell us what transpired after you bought your food?
A:
Q: NOTE: follow line of questioning.
A:

Q: You testified that PO1 Burgos waved at you to come outside. How did he do that?
A:

Q: Were you able to go outside?

A:

Q: When you went outside the store, what happened?

A:

Q: Do you remember how many people were there?

A:

Q: What did you do when you were handcuffed?

A:

Q: Did you ask them why they were arresting you?

A:

Q: Did you make a scene when they were arresting you all of a sudden?
A:

Q: If yes, did anyone witness you do the same? (Q: Will you be presenting that person
who witnessed your arrest in this Court? Q: Why not?) / If no, why not?
A:

Q: Mr. Witness, do you remember who handcuffed you during that time?
A:

Q: Can you show to this Court in the picture that was previously marked as Exhibit "F-1"
who was the person who handcuffed you?
A:

Q: Is PO1 Burgos in this picture?

A:

Q: Where is he?
A:

Q: Also, Mr. Witness, you made mention that after you were “handcuffed,” you said that
"We stayed in the car." Am I correct?
A:

Q: So you were handcuffed and brought to a car?

A:

Q: Which car did you go to?

A:

Q: Did you notice this car when you arrive at the place?
A:

Q: During the time that you were being led to the car, did you do anything in particular?
A:

Q: If yes, what did you do? / If none, why didn't you?

A:

Q: You also said that "He likewise demanded an additional fifty thousand for
inconvenience which I allegedly caused." Who is this "he" who demanded P50,000.00
from you?
A:

Q: Why did you not mention these things during your direct examination?
A:

Q: Are there other people inside the car?

A:

Q: Mr. Witness, you testified in this Court earlier as well the when you arrived at the
police station, "They asked me to surrender my phone." Who are "they"?
A:

Q: So you had with you your mobile phone the entire time, yet you did not attempt to
call your lawyer, or anyone for that matter, when you were suddenly handcuffed in 7/11
St.?
A:

Q: Were there other people when you arrived at the police station?
A:

Q: Did you actually surrender your phone to the anyone during that time?
A:

Q: You also made mention earlier that "Before calling my lawyer, I sent the earlier
mentioned screenshots to him." Am I correct?
A:

Q: You also showed this screenshot showing your exchange with a person with the
mobile number 0919999999, previously marked as Exhibit "G-1" and a Certification
from the Head Legal Division of Smart Telecom, previously marked as Exhibit "G-4," am
I correct?
A:

Q: How do you know that this is the mobile number of your lawyer?
A:

Q: Did you obtain a similar Certification with regard the mobile number with whom you
had sent the screenshots and called?
A:

Q: Wouldn't you agree with me that a prudent and innocent man would have demanded
to call his lawyer, or anyone else, in case he had been arrested without any basis at all?
NOTE: This is ARGUMENTATIVE, and will be striked out from the records, but we just
want to put this out there.
A:

Q: You made mention that a blotter was filed by your father, assisted by your counsel in
Station 6 of Brgy. Ballibago, Angeles City. When was that made?
A:

Q: And you also said that your father filed the same against the police officer who
arrested you, am I correct?
A:

Q: Was your father present during your arrest?

A:

Q: Was your counsel likewise present during your arrest?

A:

Q: Did anyone with personal knowledge as to your arrest present when the blotter was
made on that date?
A:

Q: If yes, who was it? / If no, next question.

Q: Mr. Witness, you testified that "My father assisted by my counsel filed a blotter in
Station 6 of Brgy Balibago Angeles City against the police who arrested me on January
10, 2017." Who is the police who arrested you against whom you filed a blotter against?
A:

Q: You also made mention that “An administrative case for grave misconduct and
conduct unbecoming a police officer was filed against the police officers.” So did you
file the case to ONE police officer, or to MANY police officers?
A:
*** Refer to the answer of the witness as to how many and who are the police officers
who were present during that arrest vis-à-vis on who actually made the arrest as
testified by the witness.

Q: When did you file this administrative case?

A:

Q: Who else personally know that an adminstrative case had been filed against these
officers?
A:

IF CASE IS ONLY FILED AGAINST PO1 BURGOS: Q: Mr. Witness, I am showing to

you the Transcript of Stenographic Notes of the direct examination of PO1 Burgos, the
poseur buyer, last 8 November 2017, at the time when you were likewise present in this
Court for identification. I refer you to Page 2, can you please read this part aloud for the
Court?
A: “Q: During the years that you have been in service, have you ever been subjected to
any disciplinary action or proceeding? A: No, Ma’am. I have not.”

IF CASE IS ALSO FILED AGAINST PO1 DELA ROSA: Q: Mr. Witness, I am showing to
you the Transcript of Stenographic Notes of the direct examination of PO1 Dela Rosa,
the arresting officer, last 8 November 2017, at the time when you were likewise present
in this Court for identification. I refer you to Page 2, can you please read this part aloud
for the Court?
A: “Q: During the years that you have been in service, have you ever been subjected to
any disciplinary action or proceeding? A: No, ma’am. I have not.”

Q: If the adminsitrative case had been in fact filed at the time PO1 Dela Rosa and/or
PO1 Burgos, why was the same not interposed by your counsel during their/his direct
and cross examination/s?
A: