Republic of the Philippines

9th Judicial Region

Regional Trial Court
Branch 10
Zamboanga City
People of the Philippines
Plaintiff,

Criminal Case No. _____

For Frustrated Parricide

- versus
Justinio L. Macasol
Accused.
PRE-TRIAL SUMMARY OF THE PROSECUTION
The People of the Philippines, through the undersigned City Prosecutor,
before this Honorable Court, most respectfully submit this Pre-Trial Brief:
PROPOSED STIPULATION OF FACTS
Respondents respectfully submit the following propositions for stipulation:
1. That herein victim Pearl Marjorie J. Macasol is validly married to accused
Justinio L. Macasol.
2. That they do not have any children or any other descendants and
ascendants who may inherit from them and that they are the sole heirs of
each other.
3. That victim and accused live together in one house with victims niece, a
housemaid and a houseboy.
4. That the victim was brought to Ciudad Medical after losing consciousness
on the night of January 8, 2017.
5. That accused manages the couples hardware business.
DOCUMENTS TO BE PRESENTED:
The Prosecution would like to respectfully present the following documents:
Exhibit No.
A

Documents
Complaint-Affidavit of Ms. Pearl Marjorie
J. Macasol

Purpose
To prove that Plaintiff had ingested poison
from the milk that she drank offered to her
by the accused.

Marriage Certificate of victim and accused

Income Tax Returns of Accused Justinio L.

Macasol for year 2016 and 2014

To show that the couple are legally married

to each other.
To show that Justinios business profit has
considerably went down.

Page 1 of 3

Affidavit of Mary Jane Lihay-Lihay

Affidavit of Daisy Fernandez

Ciudad Medical Billing Statement

G
H

Ciudad Medical Official Receipt No.

0000789
Lab Test Result on Urine Sample

Lab Test Result on Blood Sample

To prove that she saw accused Justinio in

the kitchen preparing milk.
To prove that the urine and blood sample
she collected from the victim are both
positive of arsenic, a poisonous substance.
To show that the victim was admitted in the
hospital and incurred expenses.
To show that the hospital billing statement
has been paid in full by the victim.
To show that the victim has ingested an
arsenic substance detected through the urine
test.
To show that the victim has ingested an
arsenic substance detected through a blood
sample.

The Prosecution would like to respectfully reserve the right to present additional
documents as may be needed to rebut evidence of the Defense.
WITNESSES TO BE PRESENTED:
The victim would like to respectfully present the following witnesses:
1. MS. PEARL MARJORIE J. MACASOL to testify that she was offered milk
by her husband which caused her stomach pain and eventually lose consciousness.
2. MS. MARY JANE LIHAY-LIHAY to testify that she was in the kitchen while
accused was preparing milk.
3. MS. DAISY FERNANDEZ to testify on her findings of the blood and urinary
laboratory tests of the victim which yielded positive for arsenic substance.
The Prosecution would like to respectfully reserve the right to present
additional witnesses as may be needed to rebut evidence of the Defense.
Respectfully submitted this 25th day of January, 2017 at Zamboanga City,
Philippines.

Zamboanga City Prosecutors Office

Pettit Barracks, Zambo. City
By:
SALI HADJULA
City Prosecutor
Roll No. 49871
MCLE Compliance No. II-0012458
Page 2 of 3

And
CHRISTELLE T. RUBIO
Asst. Prosecutor

Roll of Attorneys No. 56460

MCLE Compliance No. V 0002095, May 13, 2014

Copy furnished:
ATTY. ___________________
Counsel for the Defense
Room 200, MP Towers
Nuez Extension, Zambo. City

Page 3 of 3