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~ versus ~
For: HOMICIDE
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PRE-TRIAL BRIEF
2.1. Defendant admits that he and his colleagues were after PIM
ALRICK BARBON who was a wanted drug lord in Guihulngan City, Negros
Oriental.
2.2. Complainant will no longer pursue defendants and his colleagues
criminal and civil liabilities for the death of PIM ALRICK BARBON.
III. ISSUES TO BE TRIED
3.1. Complainant submits that the following issues put forward by the
defendant are subject to proof:
3.1.1. Defendants discharge of lawful duties
3.1.2. Defendants act of defending himself when he shot the victim
IV. EVIDENCE
4.1. Complainant intends to present the following documentary
evidence:
4.1.1. Death certificate of ALTHEA PHEM BARBON
4.1.2. Receipts corresponding to funeral expenses incurred by the
victims family
4.1.3 Receipts for other expenses incurred in connection with the death
of ALTHEA FHEM (i.e. hospital expenses, Doctors Professional Fees, etc.)
4.2. Complainant reserves the right to present any and all
documentary evidence which shall become relevant to rebut complainants
claims in the course of trial as well as any other witnesses whose testimony
will become relevant to belie defendants witnesses, if necessary.
V. RESORT TO DISCOVERY
5.1. Considering that there was no eye witness in the case, complainant
reserves the right to resort to discovery if such will be necessary in the course
of the trial.
RESPECTFULLY SUBMITTED.
Guihulngan City, Negros Oriental, Philippines, November 5, 2016.
CONFORME:
NOTICE OF HEARING
SPO1 SEVERINO TABAYACYAC
Lot 9, Block 10, Lipton Street, City of Guihulngan
Greetings:
Please be informed that the foregoing Motion for Extension of Time to
file Counter Affidavit is requested to be submitted for the consideration of the
Honorable Investigating Prosecutor immediately upon receipt hereof.
EXPLANATION
Copies of the foregoing Motion for Issuance of Hold Departure Order
were served on the Complainant by registered mail since personal service is
not practicable because of time constraints and the distance between the
office of the undersigned counsel and the residence of the Complainant.