Republic of the Philippines

REGIONAL TRIAL COURT

Seventh Judicial Region
Branch XV, Cebu City

THE PEOPLE OF THE PHILIPPINES, CRIMINAL CASE NO. 57692

Plaintiff,
-versus - for: MURDER

LIAM NEESON
Accused. NO. 1602

X -------------------------------------- X

ACCUSED TRIAL MEMORANDUM

Accused, through counsel, most respectfully alleges:

PREFATORY STATEMENT

On December 7, 2016 , Accused Liam Neeson was charged before the

Regional Trial Court for the murder of Marina Tuna, Rose Ariohan and
Peter Piper in an information, the pertinent portion of which reads:

“That on or about October 6, 2016 at around 6 o’clock in the

evening at Story Land Residences, Lancaster, Pennsylvania,
Cebu City, Philippines and within the jurisdiction of this
Honourable Court, the above named accused, conspiring and
confederating together, did then and there, knowingly,
wilfully and feloniously mauled and attacked Marina Tuna,
Rose Ariohan and Peter Piper, with treachery, evident
premeditation, and ignominy, the result of said act resulted
to the brutal death of the said victims.”

STATEMENT OF FACTS:

In order that this Honourable court may be enlightened and guided in

the judicious disposition of the above-entitled case, cited hereunder the
material, relevant and pertinent facts of the case to wit:

1. Accused is Liam Neeson, 18 years of age, single, and a resident of

Storybook Land Residences, Lancaster Pennsylvania, Cebu City.
Accused is the brother of the witness, Jake Neeson. Accused has been

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 declared missing for the last ten years and eight months, and his
whereabouts were unknown until the fateful night of the killing.

2. On the night of October 26, 2015, while the victims Marina Tuna,
Rose Ariohan, Peter Piper and Jake Neeson were searching for the
accused in Storybook Park, the accused, in a hooded coat and with a
crowbar, attacked Marina Tuna from behind and choked her thereby
causing her instantaneous death.

3. Later that night, despite the victims desperate attempt to escape, the
accused abducted Rose Ariohan and Peter Piper inside an
abandoned room. Rose Ariohan was found by witness Jake Neeson
tied up and bloodied in the aforementioned abandoned room; the
witness added that the blood seemed to be oozing out from a deep
wound on her throat. Peter Piper, who was also found dead in the
crime scene, had his right eyeball plucked from its socket. This scene
caused the witness to run but unluckily he bumped into the accused.

4. The accused, upon being confronted by the witness, Jake Neeson,

revealed his identity and confessed to the killing. After such
revelation, he grabbed the witness, threw him to the ground, pointed
his axe at him and said the words “it’s time to play again”. As the
accused was about to strike, Jake Neeson grabbed a wooden sword,
deflected the axe, stabbed the accused and ran to Police Station No. 7
on Osmena Boulevard to report the said matter.

5. Information was filed before the Cebu City Prosecutor’s Office on

November 3, 2016, and an arrest warrant dated November 11, 2016
was issued by this Honourable Court which led to the arrest of the
accused in Storybook Land Residencies by Police Operatives from
the Heinous Crimes Division stationed in Police Station No. 7 led by
SPO4 Leigh Shive. The accused was not allowed to post bail;
arraignment and trial then ensued.

6. Upon arriving at the crime scene, the police officers found three (3)
dead bodies (Exhibit A), a crowbar (Exhibit B), torn bloodied clothes
of the victims (Exhibit C), an Abaca rope (Exhibit D) and a black
hoody allegedly worn by the accused (Exhibit E) on the day of the
killing. Such items were inventoried by the officers, pre-marked by
the counsel and identified by the witnesses in accordance with the
Rules on Evidence.

7. This Honourable Court, pursuant to the requirements of the Rules of

Court, required the submission of a trial memorandum on or before
July 24, 2019. Hence, the Prosecution, acceding to such order,

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 submits this Trial Memorandum and its corresponding annexes to
this Honourable Court.

STATEMENT OF ISSUE(S)

The only issue to be resolved by this Honourable Court is whether

or not there is enough evidence to overcome the Constitutional
presumption of innocence of the accused and hold the him guilty
beyond reasonable doubt for the crime of Murder.

ARGUMENTS AND DISCUSSIONS