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G.R.No.

170863
People vs. Bago, 330 SCRA 115, April 06, 2000
People vs. Mercado, 397 SCRA 746, February 19, 2003
People vs. Fernandez, 414 SCRA 84, October 23, 2003
Bon vs. People, 419 SCRA 101, January 13, 2004
Rebucan vs. People, 507 SCRA 332, November 20, 2006
Astudillo vs. People, 509 SCRA 302, November 30, 2006
People vs. Castro, 566 SCRA 92, September 19, 2008
ANNOTATION: Rules of Circumstantial Evidence in Securing Conviction
of Accused Beyond Reasonable Doubt, 620 SCRA 581, May 14, 2010
People vs. Cristobal, 646 SCRA 599, March 30, 2011
Villarin vs. People, 656 SCRA 500, August 31, 2011
People vs. Tanchanco, 670 SCRA 130, April 18, 2012Zapanta vs.
People, 694 SCRA 25, March 20, 2013
Candelaria vs. People, 744 SCRA 178, December 08, 2014
San Diego vs. People, 755 SCRA 260, April 08, 2015
People vs. Boquecosa, 767 SCRA 610, August 19, 2015
Frontreras vs. People, 776 SCRA 152, December 07, 2015
ADVANCE DECISIONS: PEOPLE vs CRUZ, June 08, 2016

Thus, the trial court is bound to consider only the testimonial evidence
presented and exclude the documents not offered. Documents which may have
been identified and marked as exhibits during pre-trial or trial but which were
not formally offered in evidence cannot in any manner be treated as
evidence. Neither can such unrecognized proof be assigned any evidentiary
weight and value. It must be stressed that there is a significant distinction
between identification of documentary evidence and its formal offer. The former
is done in the course of the pre-trial, and trial is accompanied by the marking
of the evidence as an exhibit; while the latter is done only when the party rests

its case. The mere fact that a particular document is identified and marked as
an exhibit does not mean that it has already been offered as part of the
evidence. It must be emphasized that any evidence which a party desires to
submit for the consideration of the court must formally be offered by the party;
otherwise, it is excluded and rejected.
People vs. Villanueva, G.R. No. 181829

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