Good afternoon Your Honor, respectfully appearing as collaborating counsel for the private prosecutor Atty Geronimo Realiza. Under the direct supervision and authority of the public prosecutor.
Proposed Stipulations: Will the distinguished counsel of the accused admit the following facts: Q: Does the accused admit to be the same Belen Buenconsejo that is the employee Royal Pictures, Inc .under the name and style of Kodak express, Inc? Q Does the accused admit that she has been employed by royal express since 2009 until such time when the incident causing the filing of this case has been found out? Q: Does the accused admit that she is the cashier/OIC in the Kodak pictures marina mall branch, lapulapu city? Q; Does the accused admit the jurisdiction of this court?
Evidences I have here with me your honor object evidences which i move to be marked as exhibits a-v. However, your honor because of the voluminous number of exbibits may I move for a separate time for the pre-marking of these evidences.
Witnesses Just for the record your honor, I have four witnesses, the two are reserve, we may or may not them your honor.
In case trial I call to the witness stand my first witness your honor _____ The purpose of her testimony is to ____________ Q: Are you the same ________ who is the _______ in this case? Q: After you filed the complaint can you recall issuing a statement before Atty Geronimo Realiza? Q: I am showing you a document purporting to be a judicial affidavit, Can you please identify?
Q: On the __page please that there is a signature made by a ________, Can please identify this signature? Q: Do you affirm and confirm the truthfulness and veracity of the matters contained in your Judicial Affidvait? Q:please Refer to the attachments in your judicial affidavit, Do you affirm and confirm that the attached documents are genuine and faithful reproduction of the original?
Secretary’s certificate: This is a criminal case your honor and the injured party is the state. The state does not need authority for it to present evidence. On the issue of civil liability. Civil aspect is deemed instituted, thus sec certificate is no longer necessary.
