This document is a pre-trial brief submitted by the prosecution in the criminal case of People of the Philippines v. Edmund G. Fernandez for the crime of murder. It summarizes the admitted facts, including the identity of the accused and victim, the date and location of the killing, and jurisdiction of the court. It also lists 10 pieces of evidence that will be presented, such as affidavits from an eyewitness, arresting officer, and victim's wife, as well as autopsy reports and ballistics evidence. The brief identifies the two main issues as whether the accused committed the crime and is guilty. It lists 4 witnesses who will testify, including the eyewitness, arresting officer, victim's wife, and medical
This document is a pre-trial brief submitted by the prosecution in the criminal case of People of the Philippines v. Edmund G. Fernandez for the crime of murder. It summarizes the admitted facts, including the identity of the accused and victim, the date and location of the killing, and jurisdiction of the court. It also lists 10 pieces of evidence that will be presented, such as affidavits from an eyewitness, arresting officer, and victim's wife, as well as autopsy reports and ballistics evidence. The brief identifies the two main issues as whether the accused committed the crime and is guilty. It lists 4 witnesses who will testify, including the eyewitness, arresting officer, victim's wife, and medical
This document is a pre-trial brief submitted by the prosecution in the criminal case of People of the Philippines v. Edmund G. Fernandez for the crime of murder. It summarizes the admitted facts, including the identity of the accused and victim, the date and location of the killing, and jurisdiction of the court. It also lists 10 pieces of evidence that will be presented, such as affidavits from an eyewitness, arresting officer, and victim's wife, as well as autopsy reports and ballistics evidence. The brief identifies the two main issues as whether the accused committed the crime and is guilty. It lists 4 witnesses who will testify, including the eyewitness, arresting officer, victim's wife, and medical
This document is a pre-trial brief submitted by the prosecution in the criminal case of People of the Philippines v. Edmund G. Fernandez for the crime of murder. It summarizes the admitted facts, including the identity of the accused and victim, the date and location of the killing, and jurisdiction of the court. It also lists 10 pieces of evidence that will be presented, such as affidavits from an eyewitness, arresting officer, and victim's wife, as well as autopsy reports and ballistics evidence. The brief identifies the two main issues as whether the accused committed the crime and is guilty. It lists 4 witnesses who will testify, including the eyewitness, arresting officer, victim's wife, and medical
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Republic of the Philippines
REGIONAL TRIAL COURT
7 th Judicial Region Branch 19 Cebu, City
PEOPLE OF THE PHILIPPINES, CRIMINAL CASE NO. _____ Plaintiff, FOR: MURDER
-versus-
EDMUND G. FERNANDEZ Accused.
x-------------------------------------x
PRE-TRIAL BRIEF OF THE PROSECUTION
THE PEOPLE OF THE PHILIPPINES, t hr ough t he under s i gned Ci t y Prosecutor, before this Honorable Court, most respectfully submit this Pre-Trial Brief:
SUMMARY OF ADMI TTED FACTS AND PROPOSED STI PULATI ON OF FACTS
The following are the facts:
1. the identity of the accused charged in the information and that of the person arraigned are one and the same;
2. the identity of Dennis Beltran the victim;
3. the killing of the victim;
4. the date and places of the commission of the crime;
5. the name of the wife of the victim;
6. the jurisdiction of the Court.
EVI DENCE FOR MARKI NGS
1. Affidavit of the witness Marilou Suarez Purpose: to prove that she was present at the time of murder which took place at One Mango Ave., Gen. Maxilom, Cebu City;
2. Affidavit of the Arresting Officer Glen Fortunado Purpose: to prove that the accused was arrested by him after the accused was bumped by a vehicle after fleeing from the crime scene;
3. Affidavit of the Wife, Mrs. Mehoney Ratilla Purpose: to determine the extent of damages claimed against the accused-murderer;
4. Autopsy Report of Dennis Beltran issued by the PNP Medico Legal Dr. Caroline Cumajig Purpose: to prove the extent of the injury and the cause of death of the victim;
5. Anatomical Sketch Pur pos e: To pr ove whi ch par t of t he vi ct i m s body was s hot and t he nat ur e, extent and location of wound;
6. Paraffin test result Purpose: To prove that accused became positive of gun powder burns.
7. Gun Powder Residue Test Purpose: To determine whether the recovered firearm has been discharged.
8. Ballistics Test result Purpose: To prove that the slug recovered from the victims body came from the same gun which was recovered from the possession of Edmund G. Fernandez.
9. Firearms Verification Result Purpose: To prove that the firearms recovered from the possession of the accused is an unlicensed firearm.
10. Fired Shells
11. 4 live ammunitions
12. .45 caliber pistol
I S S U E S
1. Whether or not the accused committed the crime charged;
2. Whether or not he is guilty thereof.
W I T N E S S E S
1. Marilou Suarez to testify that she personally witness the shooting at One Mango Ave., Gen. Maxilom, Cebu City;
2. Glen Furtonado, arresting officer;
3. Mehoney Ratilla, the wife of the victim;
4. Medico Legal Dr. Caroline Cumajig, expert witness to testify the veracity of the autopsy report;