Republic of the Philippines

REGIONAL TRIAL COURT

7th Judicial Region
BRANCH 75
Bais City

PEOPLE OF THE PHILIPPINES

Plaintiff, CRIM. CASE No.
MJ2022-163-CRC
-versus-

For: Homicide
ROLAND ACOSTA y PALOMAR
Accused.
X-----------------------------------------X

PRE-TRIAL BRIEF

THE STATE, through the undersigned Associate Provincial

Prosecutor, respectfully submits the instant Pre-Trial Brief:

Theory of the case

As stated in the Information

Issue to be Resolved

Whether the accused is guilty of the offense charged in the

Information?

Documentary Evidence

Exhibit “A” - Affidavit of Complaint

“B” - Joint Affidavit of Arrest
“C” - Affidavit of Witness

Purpose:
1. To prove the existence, due execution and genuineness of the said document;
2. To prove the material facts and allegation in the Information constituting the
offense charged;
3. To prove the arrest of the accused hours after the incident; and
4. To form part of the testimony of the victim and other prosecution witnesses.
Exhibit “D” - Extract Copy of Police Blotter Report No. 2022-06-0384
“D-1” - Extract Copy of Police Blotter Report No. 2022-06-0385
“D-2” - Extract Copy of Police Blotter Report No. 2022-06-0386
“D-3” - Extract Copy of Police Blotter Report No. 2022-06-0387
“D-4” - Extract Copy of Police Blotter Report No. 2022-06-0388

Purpose:
1. To prove the existence, due execution and genuineness of the document;
2. To prove that the incident alleged in the Information was recorded in
the Police Blotter of the Manjuyod Police; and
3. To form part of the testimonies of prosecution witnesses

Exhibit “E” - Request for Post Mortem Exam

“F” - Medico Legal Certificate
“G” - Medico Legal Form
“H” - (Reserve) Death Certificate

Purpose:
1. To prove the existence, due execution and genuineness of the document;
2. To prove injuries sustained by the victim;
3. To prove cause of death of the victim; and
4. To form part of the testimonies of prosecution witnesses

Exhibit “I” - Photo of the victim

“J” - Photo of the bladed weapon

Purpose:
1. To prove the existence of the photographs;
2. To prove injuries sustained by the victim;
3. To weapon used by the accused; and
4. To form part of the testimonies of prosecution witnesses

Exhibit “K” - Knife

Purpose:
1. To prove the existence of the knife used in stabbing the victim;
2. To form part of the testimonies of prosecution witnesses

Testimonial Evidence
1. Arcenia C. Cadivida - Brgy. San Isidro, Manjuyod
2. PMSG Hitler Andalajao - Manjuyod MPS
3. Junrey K. Acosta - Brgy. Bolisong, Manjuyod
4. PMSG Roy Babor - Manjuyod MPS
5. PMSG Rollyben Raypa - Manjuyod MPS
6. Dr. Anthony R. Martinez - MHO, Manjuyod
7. Municipal Civil Registrar of Manjuyod

Purpose:
1. To prove the material facts and allegations in the Information constituting
the offense;
2. To identify and testify on the marked documentary evidence
Proposals for Admissions/Stipulations

1. Jurisdiction of the Honorable Court;

2. Identity of the accused as the person named and charged in the
Information and was arraigned;
3. The fact of death of the victim;
4. The cause of death of the victim;
5. Existence and Due Execution of the following:
a. Extract of Police Blotter

RESPECTFULLY SUBMITTED.

7 September 2023, Dumaguete City, Philippines.

CATHY D. CARDINO
Associate Provincial Prosecutor
Roll No. 52896
MCLE Compliance Cert. No. VII-0030521; valid until 4/14/2025

Copy Furnished via email:

Atty Louie Blake Sarmiento
Counsel for the Accused
PAO Bais City