Sample Formal Offer Prosecution

Republic of the Philippines Fourth Judicial Region REGIONAL TRIAL COURT Branch ___ Imus, Cavite PEOPLE OF THE PHILIPPINES, Plaintiff, Criminal Case No. 14-124 For: MURDER -versusJOEY CRUZ y VALENCIANO, Accused. x--------------------------------------------------------------------------------------x FORMAL OFFER OF DOCUMENTARY EVIDENCE PLAINTIFF by the undersigned counsel and unto this Honorable Court, most respectfully offers the following documentary and exhibits for the above titled case, to wit: EXHIBITS

DESCRIPTION

PURPOSE/S

“A”

Sinumpaang-Salaysay  To correlate the testimony in the of Ms. Dimples F. Judicial Affidavit (Exh. “C” for Arayata Plaintiff). Killing

“A-1”

Signature of Ms.  To prove that the witness duly Dimples F. Arayata executed the affidavit (Exh. “A”). Sinumpaang-Salaysay  To corroborate the testimony of the of Ms. Princess C. first witness; Atienza  To testify to the truth of the Killing affidavit executed;  To attest to the incident pertaining to the commission of the crime of murder by the accused;  To prove the fact of the crime charge against the accused; and  To establish the circumstances surrounding the commission of the crime. Signature of Ms.  To prove that the witness duly Princess C. Atienza executed the affidavit (Exh. “B”).

“B”

“B-1”

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“C”

“C-1” “D”

“D-1” “E”

“E-1”

“F”

“F-1” “G” “H” “F-1”

Judicial Affidavit of Ms. Dimples F. Arayata

 To testify as the primary witness to the commission of the crime;  To testify to the truth of the affidavit executed;  To attest to the incident pertaining to the commission of the crime of murder by the accused;  To prove the fact of the crime charge against the accused; and  To establish the circumstances surrounding the commission of the crime. Signature of Ms.  To prove that the witness duly Dimples F. Arayata executed the affidavit (Exh. “C”). Judicial Affidavit of  To prove the performance of his PO2 David P. duty as First Responder and Nepomuceno Investigator within the scope of his duty and regular performance of duty;  To testify to the truth of the affidavit executed;  To identify the victim and the accused. Signature of PO2  To prove that the witness duly David P. Nepomuceno executed the affidavit (Exh. “D”). Letter Endorsement  To provide the court information to the Office of the pertaining to the commission of Provincial the crime of murder by the Prosecutor/Police accused. Report Signature of PO2  To prove that the witness duly David P. Nepomuceno executed the Letter Endorsement/Police Report (Exh. “E”). Pinagsamang  To correlate the testimony in the Sinumpaang-Salaysay Judicial Affidavit of the second of PO2 David P. witness. Nepomuceno and Mr. Jerry Pascua Signature of PO2  To prove that the witness duly David P. Nepomuceno executed the affidavit (Exh. “F”). Crime scene picture of  To provide the court information the body of the victim as to the physical condition of the victim.  Medical Necropsy and  To submit to the court information Toxicology of the cause of death of the accused  To corroborate the testimony of the first witness;  To correlate the report with the Page 2 of 4

commission of the crime.

“F-2” “G-1”

Picture of dead Maria Labo Crime Scene picture of the kitchen

 To support the proof of the death of the accused.  To provide the court information as to the place where the crime was committed  To corroborate the testimony of the two witnesses presented.

“G-2”

Crime scene picture of  To prove the existence of one of the Cauldron the instruments/tools used in killing the victim;  To corroborate the testimony of the two witnesses presented.

“G-3”

Crime Scene picture of the body on the table, covered with the Blanket (“C-1”)

 To provide the court information as to the circumstance of the victim;  To corroborate the testimony of the two witnesses presented.

Aforesaid exhibits are being offered to prove that the crime and accusation against the accused was true and committed at the address indicated in the Complaint. WHEREFORE, premises considered, it is most respectfully prayed to this Honorable Court that the foregoing object and documentary exhibits be admitted for which each and all said exhibits were offered in proving the claims of the complainant/s and with the formal submission of the aforesaid coupled with the testimonies of the witness who testified thereon. Makati City. August 11, 2014

BIAG NI LAM-ANG City Assistant Prosecutor

NOTICE

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The Hon. Clerk of Court RTC Branch ___ Makati City GREETINGS: Please submit the foregoing Formal Offer for the consideration and approval of the Honorable Court immediately upon receipt thereof.

BIAG NI LAM-ANG City Assistant

Prosecutor Copy Furnished: Counsel for the Accused EXPLANATION

Copies of the foregoing Formal Offer are served upon counsel of the accused and filed with the Court by personal service.

BIAG NI LAM-ANG City Assistant

Prosecutor

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