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Pre-Trial Guide: COMES NOW, ACCUSED, Assisted by The Undersigned Counsel and

This document is a pre-trial guide submitted by the defense counsel for accused Arman Carig Antipala in a criminal drug case. It proposes 7 stipulations regarding the lack of personal knowledge of investigating officers and forensic experts. It also indicates the accused will testify in his defense and his judicial affidavit will be submitted as evidence. The document was filed with the Regional Trial Court of Davao del Norte, Philippines.

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Rothea Simon
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168 views2 pages

Pre-Trial Guide: COMES NOW, ACCUSED, Assisted by The Undersigned Counsel and

This document is a pre-trial guide submitted by the defense counsel for accused Arman Carig Antipala in a criminal drug case. It proposes 7 stipulations regarding the lack of personal knowledge of investigating officers and forensic experts. It also indicates the accused will testify in his defense and his judicial affidavit will be submitted as evidence. The document was filed with the Regional Trial Court of Davao del Norte, Philippines.

Uploaded by

Rothea Simon
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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Republic of the Philippines

REGIONAL TRIAL COURT


11th Judicial Region
Branch

PEOPLE OF THE PHILIPPINES Criminal Case No. 27419 and 27420


Plaintiff,
FOR: VIOL. Of Sec. 5 and 11, ART.
-versus- II of R.A 9165 KNOWN AS THE
COMPREHENSIVEDANGEROUS
ARMAN CARIG ANTIPALA DRUGS ACT.
Accused.
x-----------------------------------------x

PRE-TRIAL GUIDE

COMES NOW, ACCUSED, assisted by the undersigned counsel and


unto this Honorable Court, respectfully submit this Pre-Trial Guide and
herein propose the following stipulations, THAT:

STIPULATIONS ADMITTE DENIED


D

1. The investigating officer has NO personal


knowledge of the buy-bust operation
conducted with the regard to this case.

2. The receiving officer and the forensic


chemical officer of the Davao del Norte
Police Provincial Crime Laboratory have NO
personal knowledge on how the accused was
arrested.

3. The receiving officer and the forensic


chemical officer of the Davao del Norte
Police Provincial Crime Laboratory have NO
personal knowledge on how and where the
specimen/s was/were marked by the
arresting and seizing officer.

4. The receiving officer and the forensic


chemical officer of the Davao del Norte
Police Provincial Crime Laboratory have NO
personal knowledge on who took the custody
of the specimen/s from the place of arrest
and /or seizure to the office of the team that
conducted the drug operation.

5. The receiving officer and the forensic


chemical officer of the Davao del Norte
Police Provincial Crime Laboratory have NO
personal knowledge on how the specimen/s
was/were transported from the place of
arrest or seizure to the office of the team

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that conducted the drug operation.

6. The receiving officer and the forensic


chemical officer of the Davao del Norte
Police Provincial Crime Laboratory have NO
personal knowledge on how the specimen/s
was/were kept at the office of the team that
conducted the drug operation.

7. As to the witness of the defense, we will be presenting the following:

a. The Accused himself,

8. With respect to the documentary evidence, with reservationto mark


the Judicial Affidavit of the Accused as Exhibit 1.

WHEREFORE, premises considered, it is respectfully prayed of this


Honorable Court that the proposed stipulations be duly noted in the records
of the case.

RESPECTFULLY SUBMITTED.City of Tagum, Davao del Norte,


Philippines. October 4, 2021.

By:

PUBLIC ATTORNEY’S OFFICE


Regional Office XI
Tagum District Office
Counsel for the Accused

ROTHEA A. SIMON
Public Attorney II
Roll No. 67938
IBP No. 123889/Davao City
MCLE Compliance No. VI -0009812/April 14, 2022

Copy furnished:

Office of the City Prosecutor


Tagum City, Davao del Norte

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