MOCK TRIAL SCRIPT FOR DRUGS

ARRAIGNMENT & PRE-TRIAL

REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION
REGIONAL TRIAL COURT
BRANCH 115, PASAY CITY

PEOPLE OF THE PHILIPPINES

CRIM CASE NO. R-PSY-23-05678-CR

-versus- For: Violation of Sec. 5 Art. II of

RA 9165 also known as Comprehensive
Dangerous Drugs Act of 2002

ALLEN LLOIDE BANTIGUE Y FERNANDEZ,

AND BIEN LOUISE MANGACU Y MANALO
Accused.

x---------------------------------------------------------- x

PRESENT
Hon. Gregorio Pimentel Jr. – Presiding Judge
Atty. Carl Matthew R. Alcantara - Clerk of Court, Branch XVI
Janine May G. Salvador - Stenographer

ARRAIGNMENT

Clerk of Court: All rise! Court is now in session, witness the Honorable Judge Gregorio
(Alcantara) Pimentel, Jr. presiding. Silence is hereby enjoined. Let us bow our heads in
prayer.

(Tatayo lahat)

Almighty God, we stand in Your Holy Presence as our Supreme Judge. We

humbly beseech You to bless and inspire us so that what we think, say and
do will be in accordance with Your will. Enlighten our minds, strengthen our
spirit and fill our hearts with fraternal love, wisdom and understanding, so
that we can become effective channels of truth, justice and peace. In our
proceedings today, guide us in the path of righteousness for the fulfillment of
Your greater glory. Amen

Judge: (Judge bangs gavel once, everybody sits down.) Call the cases.
Clerk of Court: Please be seated

For Arraignment: Criminal Case PSY-0014-07 People of the Philippines vs.

JAN SARMIENTO, PAUL JASON GUIEB, GEE MARIE G. GALANG,
for the Violation of Section 5 in relation to Section 26 of Republic Act
Accused. No. 9165, otherwise known as, the
Comprehensive Dangerous Drugs Act

Defense Counsel: Yes your honor, Accused Sarmiento, Accused Guieb and Accused Galang
are all present. Please approach the bench.
Judge: Are you ready for Arraignment?
Prosecutor/ Yes. Your Honor. We are ready.
Defense:
Judge: (calls the accused.) What is your highest educational attainment? How do
you want the information to be read to you?
Accused (answer)

In english, your honor

Clerk of Court Please Stand up Sir. (Accused will stand and proceed to the right portion of
(Court the room in front of the court interpreter)
Interpreter):
Criminal case No. PSY-0014-07. People of the Philippines vs. JAN
SARMIENTO, PAUL JASON GUIEB, AND GEE MARIE G. GALANG

File: Information Accused Sarmiento, Accused Guieb and Accused Galang commit a crime for
Violation of Sec. 5 in relation to Sec. 26 of RA 9165 also known as
Dangerous Drugs Act.

That on or about the 3rd day of February 2023 in Taft Avenue, Pasay City,
Philippines, and within the jurisdiction of this Honorable Court, the above-
named accused conspiring, confederating and mutually helping with one
another, did then and there willfully, unlawfully, feloniously and knowingly
transport and deliver marijuana fruiting tops with a total weight of FORTY
EIGHT THOUSAND FIVE HUNDRED SIXTY FIVE POINT SIXTY EIGHT
(48,565.683 grams) with the use of Red Owner Type Jeep with plate no. XYZ
888, without the necessary authority or permit from the proper government
authorities.

Contrary to law.

(signed)
Prosecutor

Judge: Do you understand the crime charged against you?

Accused: Yes, your honor.
Judge: How do you plea, Accused Sarmiento? (Inaamin mo ba to o hindi)
Accused: Not guilty, Your Honor.
Judge: Do you understand the crime charged against you?
Accused: Yes, your honor.
Judge: What is your plea, Accused Guieb? (Inaamin mo ba to o hindi)
Accused: Not guilty, Your Honor.
Judge: Do you understand the crime charged against you?
Accused: Yes, your honor.
Judge: What is your plea, Accused Galang? (Inaamin mo ba to o hindi)
Accused: Not guilty, Your Honor.
Court Interpreter: Your Honor, all the Accused pleaded not guilty to the crime charged in
Criminal Case No. PSY-0014-07
Judge: Let it be on the record that the accused pleaded not guilty for the crime
charged in Criminal Case No. PSY-0014-07. The information was read to
them in English, a language known and understood by the all the accused.
Also, Atty.Seifred Loro the defense counsel of the accused assisted him in
this arraignment.

Prosecutor: Your honor, we move for the amendment of the information to include the
maternal surname of the three accused, it being a matter of form.
Defense Your Honor, we concur with the motion of the opposing party.
Prosecutor: Your honor, we would like to set the case for pre-trial on September 22,
2023.
Defense: Yes your Honor. We submit to the proposed date of the opposing party.
Ok set the pre-trial of the case on September 22, 2023. We only have one
case for today?
Court Yes, your honor.
Stenographer:
Judge; ORDER When this case was called for arraignment, accused JAN SARMIENTO,
 PAUL JASON C. GUIEB, AND GEE MARIE C. GALANG appeared
with his counsel ATTY. MIKAELA CURIOSO the prosecution
represented by Prosecutor RIA MARQUEZ and the complainant likewise
appeared, after the reading of the information to all the accused In a language
with which all accused understands, each of the accused freely and
voluntarily entered a plea of not guilty. Enter a negative plea into the record
of the case pre-trial is set today. So ordered.

PRE-TRIAL CONFERENCE

Clerk of Court: Criminal Case No. PSY-0014-07 People of the Philippines v. JALLEN
LLOIDE BANTIGUE, AND BIEN LOUIS MANGACUfor Violation of Sec.
5 in relation to Sec. 11 of RA 9165 also known as Dangerous Drugs Act, for
pre-trial conference.

Judge: Appearances?
Prosecutor: For the prosecution, Your Honor, John Daedalus Misola, appearing for the
state, ready your Honor.
Defense Good afternoon Your Honor, for the defense, representing the accused, I am
Seifred Loro, defense counsel and I am ready.
Judge: Are parties willing to agree to enter into a plea-bargaining?
Prosecutor Your Honor Please, the prosecution does not desire to enter into plea-
bargaining
Defense: Your Honor Please, the defense does not desire to enter intoo plea-bargaining
Judge: Alright. Let’s proceed with the pre-trial. Are the counsels ready?
Prosecutor/ Yes. Your Honor
Defense:
Stipulations and Admissions
Judge: Any stipulations or admissions from the prosecution?
Prosecutor: Yes Your Honor, We would like to stipulate on the following:

The personal circumstances of the accused, ALLEN LLOIDE BANTIGUE,

AND BIEN LOUIS MANGACU in the Information and arraignment are one
and the same.
Judge: Atty. – are you joining the stipulation of the prosecutor?
Defense Counsel: Yes, Your Honor. We admit.
Prosecutor: The Honorable Court has jurisdiction over the person of the two accused and
the subject matter of this case.
Defense Counsel: Yes, Your Honor. We admit.
Prosecutor: We stipulate that the date and place of the alleged commission of the crime
was on Septemeber 1, 2023 and in the City of Pasay.
Defense Counsel: Yes, Your Honor. We admit.
Prosecutor: Yes Your Honor, We would like to stipulate on the following:
That the two accused were caught in flagrante delicto possessing
methamphetamine chloride with a total weight of 0.1 grams
Defense Counsel: No, Your Honor. We don’t admit.
Prosecutor: That the inventory, marking, as well as the photographing of all the items
were witnessed and conducted in the presence of the suspects, Barangay
Captain (Marvin Batoctoy), Media representative (Geomari Bigalbal), and
the DOJ representative
Defense Counsel: No, Your Honor. We don’t admit..
Prosecutor: That would be all for the prosecution, your Honor
Judge: Defense Counsel, any proposal for stipulations or admissions?
Defense Counsel: Your Honor, Accused herein proposed to adopt its own narration of facts
based from the counter-affidavit it submitted before the City Prosecutor’s
Office.

Marking of Exhibits – Prosecution

Judge: Alright, now, we proceed to the pieces of evidence and witnesses to be
presented by both parties…documentary and object exhibits for the
prosecution?
Prosecutor: Yes, your Honor. I have here with me your Honor documentary and object
evidence which I move to be marked as Exhibit A to O, respectively.

Your Honor, the prosecution prays that:

1. Joint Complaint Affidavit of Police Chief Master Marla Aldemita

and Police Staff Sergeant Christian Asistores consisting of 4 pages
dated 1st day of September 2023; The 1st page as Exhibit A, 2nd
page as Exhibit A-1, 3rd page as Exhibit A-2, and the 4th page as
Exhibit A-3, with signatures appearing on the 4th page 1 st is the
signature of PCM Marla Aldemita as A–3-a and the signature of PSG
Christian Asistores as A-3-b;
2. Witness Affidavit of PMAJ Richard Cairo consisting of 3 pages dated
September 1, 2023; The 1st as Exhibit B, 2nd page as Exhibit B-1,
and the 3rd page as Exhibit B-2, and the signature of PMAJ Richard
Cairo appearing on the 2nd page be marked as B-1-a ;
3. Witness Affidavit of PCMS Marla Aldemita consisting of 3 pages
dated September 1, 2023; The 1st page as Exhibit C, 2nd page as
Exhibit C-1, and the 3rd page to be marked as Exhibit C-2, and the
signature of PCMS Marla Aldemita appearing on the 2nd page as C-
1-a;
4. Witness Affidavit of PSSG Sitti Mandong consisting of 3 pages dated
September 1, 2023; the 1st page as Exhibit D, 2nd page as Exhibit D-
1, and the 3rd page as Exhibit D-2, and the signature PSSG Sitti
Mandong appearing on the 2nd page as D-1-a;
5. Witness Affidavit of Brgy Kagawad Marvin Batoctoy consisting of 2
pages dated September 3, 2023; 1st page as Exhibit E, 2nd page as
Exhibit E-1, and the signature of Marvin Batoctoy appearing on the
2nd page as Exhibit E–1-a;
6. Witness Affidavit of Geomari Bigalbal, media representative
consisting of 2 pages dated September 4, 2023, 1st page as Exhibit F,
and 2nd page as Exhibit F-1 and the signature of Geomari Bigalbal
appearing on the 2nd page as F–1-a;
7. Witness Affidavit of Jan Malab, DOJ representative consisting of 3
pages dated September 5, 2023, 1st page as Exhibit G, 2nd page as
Exhibit G-1, and the signature appearing on the 2nd as G-1-a;
8. (4 Signatures) A copy of the Receipt and Inventory of Property
Seized consisting of 1 page dated September 1, 2023 as Exhibit H the
receipt contains 4 signatures 1st signature of Anthony Magtangob,
Seizing officer as Exhibit H-1, signature of Marvin Batoctoy as
Exhibit H-2, signature of Geomari Bigalbal to be marked as Exhibit
H-3, signature of Jan Malab as Exhibit H-4;
9. A copy of the Memorandum for the Chief Regional Crime Lab Office
3 consisting of 1 page dated September 3, 2023 to be marked as
Exhibit I and the signature of PMAJ Richard Cairo appearing thereon
as Exhibit I-1;
10. (3 Signatures) A copy of the Forensic Chemist Certification
consisting of 2 pages dated September 3, 2023, 1st page to be as
Exhibit J, 2nd page as J-1 and the signature of Joderick Menorca,
Forensic Chemist appearing on the 2nd page thereon as Exhibit J-1-a,
signature of Chief Inspector Roselle Santiago on the 2nd page as
Exhibit J-1-b, and Administering Officer Dawn Santos as J-1-c;
11. (2 signatures) A copy of The Chain of Custody Form consisting of 1
page dated September 3, 2023 as Exhibit K and the signature of
PCMS Marla Aldemita as Exhibit K-1, and the signature of PMAJ
Ivan Tello as Exhibit K–2;
12. As documentary evidence, pictures taken during the operations as
Exhibit L;
13. As Object Evidence, a clear plastic sachet containing the shabu
(SMP/QW-09-10-1 IABA) weighing 0.1 grams as Exhibit M;
14. As object evidence, a 1000-peso bill (Serial Number AB 1234) used
as marked money as Exhibit N.
15. Last is the pre-operations clearance consisting of 2 pages. 1 st page as
Clerk of Court: Show your documents to the Defense. Does the defense admit the
genuineness and due execution of the documents?

Defense Counsel: Yes, Your Honor.

Clerk of Court: The Defense admits the genuineness and due execution of Exhibits A to H.
Judge: Atty. Seifred, do you have any documentary and object evidence for
marking?
Defense Counsel: Yes, your Honor. I have here with me your Honor documentary and object
evidence which I move to be marked as Exhibit 1 to 4, respectively. We
respectfully Your Honor to include the purposes of each of our piece of
evidence:

1. Counter-affidavit of Jan Sarmiento consisting 3 pages to be marked as

Exhibit “1”, “1-a”, “1-b” and the signature appearing thereon as Exhibit “1-a-
1”

2. Counter-affidavit of PAUL JASON C. GUIEB dated February 07, 2023

consisting 3 pages to be marked as Exhibit “2”, “2-a”,“2-b” and the signature
appearing thereon as Exhibit “2-b-1”

3. Counter-affidavit of GEE MARIE G. GALANG dated February 07, 2023

consisting 3 pages to be marked as Exhibit “3”, “3-a”, “3-b” and “3-c”

4. A copy of Inventory Report consisting of 1 page dated February 3, 2023 to

be marked as Exhibit “4”

The defense, Your Honor, reserves its right to introduce submarkings to the
pre-marked exhibits and present other object or documentary evidence
during the course of the trial, subject to further directions and limitations
that this Honorable Court may impose.

Clerk of Court: Show your documents to the Prosecution. Do you admit the genuineness and
due execution of Exhibits 1-4 of the defense?

Prosecution: Yes, Your Honor. We admit the genuineness and due execution of Exhibits
1-8 of the defense.
Clerk of Court: The Prosecution admits the genuineness and due execution of Exhibit 1-4
Judge: Your witness, Prosecutor?
Prosecutor: Your honor, the prosecution have seven (7) witnesses.

The following shall be the witnesses for the Prosecution.

1. Police Major Richard CAIRO, Police Chief Master Marla
ALDEMITA, and Police Chief Master Sittie MANDONG who will
testify on the facts and circumstances of the buy-bust operations and
the Arrest of the Accused

2. Police Major Joderick MENORCA, who will testify on the forensic

results of the substance seized from the accused to prove that the
substance is a dangerous drug

3. Kagawad Marvin BATOCTOY, one of the witnesses of the buy bust

operations

4. Mr. Geomari BIGALBAL, media representative from Friday News,

one of the witnesses of the buy bust operations

5. Mr. Jan MALAB, representative from DOJ, one of the witnesses of

the buy bust operations
6.?
7.?

Furthermore, the prosecution reserves the right to present other

 witnesses not herein enumerated as deemed necessary.

Judge: Your witness, Counsel?

Defense Counsel: Your honor, I have three (3) witnesses. We set forth their purposes for
testifying:

1. Ms. Gee Marie Galang, as accused. Purpose: To establish the fact that she
has no knowledge that there was a bag of marijuana inside the vehicle of
Sarmiento and reiterating that she was just inside the vehicle with the sole
purpose of bringing her daughter to the hospital.

2. Mr. Paul Jason C. Guieb, as accused. Purpose: To establish the fact that he
did not acknowledge the ownership of plastic bags.

3. Mr. Jan Sarmiento, as accused. Purpose: To establish the fact that he does
not own the 5 plastic bags allegedly containing marijuana.

The defense counsels reserve the right to present other

witnesses not herein enumerated as deemed necessary.

Issues
Judge: What is the issue to be resolved by the Court?
Prosecutor: Whether the two accused are guilty for violation of Sec.5 of Art. II of R.A.
9165 or more commonly known as the Dangerous Drugs Act.
Judge: Counsel, do you concur with the issue proposed by the public prosecutor?
Defense Counsel: No, Your Honor.
Judge What are your proposed issues defense counsel?
Defense Counsel We propose following issues to be resolved:

1. Whether or not the accused were illegally arrested and/or searched for the
contraband for failure of the arresting policemen to secure and present
validly issued warrant of arrest and search warrant.

2. Whether or not the accused is guilty for violation of Section 5 in

conjunction with Section 26 of R.A. 9165, more commonly known as the
Dangerous Drugs Act.

3. Whether or not the prosecution established the unbroken chain of custody

of the drug seized from the accused.

Judge: Any other matter to be taken up by the Court?

Prosecutor/ No, other matter. Your Honor.
Defense:
Prosecutor: There being no other matter to be discussed, the prosecution moves for the
termination of the pre-trial.
Defense The defense adopts, the same manifestion.
Judge: ORDER When this case was called for pre-trial accused, All accused JAN
SARMIENTO, PAUL JASON C. GUIEB, and GEE MARIE C. GALANG
appeared with their Counsel SEIFRED LORO the prosecution represented by
Public Prosecutor ELENA ANGELA MANANGHAYA and the complainant
likewise appeared. The court asked the parties whether they have arrived at2
an amicable settlement for the civil aspect of this case for plea bargaining
agreement and the answer was in the negative. The prosecution started with
a proposal or stipulation of facts for admission by the defense and vice versa.
After that prosecution proceeded with the marking of its evidence starting
from Exhibit A up to J including their submarking. Likewise the defense also
started with the markingof its evidence from exhibit 1 up to exhibit 7 and the
submarking inclusive. Henceforth, the parties stated the issues to be tackled
in this case. After that the prosecution stated the number of witnesses to be
presented by naming each and likewise the defense also stated the number of
 witnesses and stated the names to be presented during the trial.

There being no matters to be discussed in the pre-trial conference, the

procession moved for the termination of the pre-trial to which the defense
adopted the same manifestation. Upon motion of the parties the pre-trial is
now deemed terminated. Initial presentation of prosecution evidence is set on
Oct 6, 2023.

TRIAL PROPER (PRESENTATION OF WITNESS)

REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION
REGIONAL TRIAL COURT
BRANCH 115, PASAY CITY

PEOPLE OF THE PHILIPPINES

CRIM CASE NO. R-PSY-23-
05678-CR

-versus- For: Violation of Sec. 5 Art. II of

RA 9165 also known as Comprehensive
Dangerous Drugs Act of 2002

ALLEN LLOIDE BANTIGUE Y FERNANDEZ,

AND BIEN LOUISE MANGACU Y MANALO
Accused.
x x

PRESENT
Hon. Gregorio Pimentel Jr. – Presiding Judge
Atty. Carl Matthew R. Alcantara - Clerk of Court, Branch XVI
Janine May G. Salvador - Stenographer

TRIAL (PRESENTATION OF WITNESS)

Clerk of Court: All rise! Court is now in session, Honorable Judge Gregorio
Pimentel, Jr. presiding. Silence is hereby enjoined.

Judge: (Judge bangs gavel once) Please be seated. Call the cases.

Clerk of Court: Good evening. Criminal Case 87470 People of the Philippines vs.
Felipe Bilo Seva Jr. for the crime of murder.

Judge: Counsels, make your appearances.

Prosecutor 1: Your Honor, I am Public Prosecutor Mikee Clamor, appearing for the
People.

Prosecutor 2: Your Honor, I am Public Prosecutor Aries Karlo Jude D. Lazaro,

appearing for the People.

Prosecutor 3: Your Honor, I am Public Prosecutor Leandro Jose G. Abiog, Jr.

appearing for the People.
 Your Honor, I am Atty. John Abrazaldo appearing for the Accused.
Defense Counsel 1:

Defense Counsel 2: Your Honor, I am Atty. Jan Sarmiento appearing for the Accused

Defense Counsel 3: Your Honor, I am Atty. Elizabeth Ngo appearing for the Accused

Judge: Is the prosecution ready?

Prosecutors: (Stand Up) Yes Your Honor.

Judge: Is the defense ready?

Defense Lawyers: (Stand Up) Yes Your Honor.

Judge: Does the prosecution wish to call any witnesses?

Witness 1 ( )
Prosecutor: () Defense Lawyer: ()

Direct Examination of Witness 1 ( )

P1:
W1:

Witness 2 ( )
Prosecutor: () Defense Lawyer: ()

Direct Examination of Witness 2 ()

P2:
W2:

Witness 3 ( Sittie Mandong)

Prosecutor: () Defense Lawyer: ()
P3:
W3:
P3:
W3:

Direct Examination of Witness 3 (Sittie Mandong)