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    Pre Trial Brief Prosecution

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    Lawrence Ȼaballo Biol
    This document is a pre-trial brief submitted by prosecutors in the criminal case of People of the Philippines vs. Juan C. Dela Cruz for the crime of qualified theft. It lists admitted facts such as the identities of the accused and victim. It also outlines the evidence that will be presented, including affidavits and documents to prove ownership of the stolen property. Finally, it lists the issues to be determined, witnesses, and proposed trial dates.

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    © All Rights Reserved
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    Pre Trial Brief Prosecution

    Uploaded by

    Lawrence Ȼaballo Biol
    137 views3 pages
    This document is a pre-trial brief submitted by prosecutors in the criminal case of People of the Philippines vs. Juan C. Dela Cruz for the crime of qualified theft. It lists admitted facts such as the identities of the accused and victim. It also outlines the evidence that will be presented, including affidavits and documents to prove ownership of the stolen property. Finally, it lists the issues to be determined, witnesses, and proposed trial dates.

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    PRE-TRIAL-BRIEF-PROSECUTION

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    This document is a pre-trial brief submitted by prosecutors in the criminal case of People of the Philippines vs. Juan C. Dela Cruz for the crime of qualified theft. It lists admitted facts such as the identities of the accused and victim. It also outlines the evidence that will be presented, including affidavits and documents to prove ownership of the stolen property. Finally, it lists the issues to be determined, witnesses, and proposed trial dates.

    Copyright:

    © All Rights Reserved
    Download as DOC, PDF, TXT or read online from Scribd
    Download as doc, pdf, or txt
    137 views3 pages

    Pre Trial Brief Prosecution

    Uploaded by

    Lawrence Ȼaballo Biol
    This document is a pre-trial brief submitted by prosecutors in the criminal case of People of the Philippines vs. Juan C. Dela Cruz for the crime of qualified theft. It lists admitted facts such as the identities of the accused and victim. It also outlines the evidence that will be presented, including affidavits and documents to prove ownership of the stolen property. Finally, it lists the issues to be determined, witnesses, and proposed trial dates.

    Copyright:

    © All Rights Reserved
    Download as DOC, PDF, TXT or read online from Scribd
    Download as doc, pdf, or txt
    of 3

    Republic of the Philippines

    REGIONAL TRIAL COURT


    10th Judicial Region
    Branch 30
    Surigao City

    PEOPLE OF THE PHILIPPINES,


    Plaintiff,
    CRIMINAL CASE NO. 8240
    FOR: QUALIFIED THEFT
    Art. 310 Revised Penal Code

    - versus -

    JUAN C. DELA CRUZ,


    Accused.
    x-----------------------------------------------x

    PRE-TRIAL BRIEF OF THE PROSECUTION

    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 identity of Juan C. Dela Cruz as charged in the
    information and that of the person arraigned are one and the
    same;
    2. The identity of Roldan Figueras, the victim;
    3. The fact of gathering of coconuts from the victim’s
    plantation;
    4. The date and place of the commission of the crime.
    EVIDENCE FOR MARKINGS

    1. Affidavit of Roldan A. Figueras


    Purpose: to prove the facts and circumstances attending the
    date of the commission of the crime on July 25, 2019 ;
    2. Affidavit of Engr. Jacob A. Rogador
    Purpose: to corroborate the testimony of Roldan A. Figueras;
    3. Original Certificate of Title No. 1068
    Purpose: to prove that Roldan A. Figueras is the registered
    owner of the land;
    4. Tax Declaration No. 1107
    Purpose: to prove ownership over the land;
    5. Copy of the Certificate of Barangay Conciliation
    Purpose: to prove that the matter wasto the Office of the
    Barangay Captain of Brgy. Togbongon, Surigao City for
    Barangay Conciliation in compliance with the condition
    precedent to the filing of the criminal case.

    ISSUES
    1. Whether or not the accused committed the crime of
    Qualified Theft (Violations of Article 310 of the Revised
    Penal Code) as charged;
    2. Whether or not they were guilty thereof.

    WITNESSES
    1. Roldan A. Figueras to testify that a crime of qualified
    theft took place;
    2. Engr. Jacob A. Rogador to testify that he was with the
    complainant when the crime took place;
    3. Brgy. Chairman Eugene E. Deguino to testify that no
    settlement was reached between Roldan A. Figueras and Juan
    C. Dela Cruz.
    TRIAL DATES
    Specifically all Fridays of the month, with the regular
    appearance of the undersigned city prosecutors before this
    Honorable Court.

    RESPECTFULLY SUBMITTED.
    Surigao City, Philippines, March 3, 2020.

    SURIGAO CITY PROSECUTOR’S OFFICE


    Ramon Q. Avanceña Hall of
    Justice
    Surigao City

    By:

    VANNESA R. COMPASIVO
    Assistant City Prosecutor
    Roll No. 67890 / 5-2-07
    IBP. No. 667899 / 12-29-07
    MCLE Exempt
    PTR Exempt

    And

    LAWRENCE C. BIOL
    Assistant City Prosecutor
    Roll No. 67891 / 5-2-07
    IBP No. 667900 / 12-29-07
    MCLE Exempt
    PTR Exempt
    Copy furnished:

    ATTY. HAZEL C. ACERO


    Counsel for the Defense
    Room 200, New Valentine Bldg.
    Rizal Corner Narciso St.
    Brgy. Washington Surigao City

    Received by:___________
    Date: ___________

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