REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

FIRST JUDICIAL REGION
BRANCH 15, LAOAG CITY
PEOPLE OF THE PHILIPPINES,
Plaintiff,
CRIMINAL CASE NO. 069-15
-versusFor:
VERGEL Agong KATAKUTAN and
XANDER Boy epal RUIZ,

Kidnapping

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

PRE TRIAL BRIEF

COMES NOW, the undersigned Deputy City Prosecutor unto this
Honorable Court, most respectfully submits his Pre-Trial Brief, to wit:
PROPOSED STIPULATIONS OF FACTS
1. The identity of the accused as the same person charged and
arraigned.
2. That the accused and victim knew each other.
3. That the victim was with the accused for almost four (4) days or
from February 6 to February 10, 2015.
DOCUMENTARY EVIDENCE
1. Exhibit A The sworn statement of BENITO Macho BROBAK;
2. Exhibit B The sworn statement of SPO 1 Teng K. Iddot;
3. Exhibit C The sworn statement of SPO 1 Cimo M. Lakas;
4. Exhibit D The sworn statement of SPO 1 Freddy G. Agila;
5. Exhibit E The extract copy of the Police Blotter Entry No.
13416 in the Police Station of Laoag City; and
6. Exhibit F The photographs of the evidence recovered which
was allegedly used by the accused.
TESTIMONIAL EVIDENCE
1. BENITO Macho BROBAK to testify to prove that he was
wilfully detained by the accused and the latter deprived him of his personal
liberty for almost four (4) days;

2. SPO 1 Teng K. Iddot to testify to prove that he was one of the

officers who arrested the accused who were then with the victim;
3. SPO 1 Cimo M. Lakas to testify to prove that he was one of the
officers who arrested the accused who were then with the victim; and
4. SPO 1 Freddy G. Agila to testify to prove that he was one of the
officers who arrested the accused who were then with the victim
LEGAL ISSUES:
1. Whether or not the accused are guilty of as charged.
2. Whether or not the victim was deprived of his personal liberty by
the accused.
3. Whether or not there is conspiracy among the accused.
RESPECTFULLY SUBMITTED.
Laoag City, April 20, 2015.
JOSE MANALO
Deputy City Prosecutor
Roll No. 12345
IBP No. 54321
MCLE V 083101 6/25/13

NOTICE
The Clerk of Court
RTC-Branch 14
Laoag City
GREETINGS!
Please submit the foregoing Pre-Trial Brief for the kind consideration
and approval of the Most Honorable Court.

JOSE MANALO