Republic of the Philippines

Central Visayas Judicial Region

REGIONAL TRIAL COURT
Branch 50, Loay, Bohol

PEOPLE OF THE PHILIPPINES,

Criminal Case No. _____
-versus- For: Illegal Possession and
Sale of Dangerous Drugs

Juan Dela Cruz

Accused.
x--------------------------------------------------------------------------------------x

FORMAL OFFER OF DOCUMENTARY EVIDENCE

Complainant the undersigned prosecutor subbmits 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 of Purita  To correlate the testimony in the Judicial

Limpio Affidavit (Exh. “C” for Plaintiff).

“A-1” Signature of Purita Limpio  To prove that the witness duly executed the
affidavit (Exh. “A”).
“B” Sinumpaang-Salaysay of Juan  To corroborate the testimony of the first witness;
Dela Cruz  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 instigation to the
defendant by SPO3 Armando Mondragon
 To establish the circumstances surrounding the
said instigation
“B-1” Signature of Juan Delacruz  To prove that the witness duly executed the
affidavit (Exh. “B”).
“C” Judicial Affidavit of Purita  To testify as the primary witness to the
Limio instigation of SPO3 Armando Mondragon;
 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.

Page 1 of 3
 “C-1” Signature of Purita Limpio  To prove that the witness duly executed the
affidavit (Exh. “C”).
“D” Judicial Affidavit of Juan Dela  To prove the that Defendant acted on the order
Cruz and instigation of SPO3 Mondragon.
 To testify to the truth of the affidavit executed;
 To identify the victim and the accused.

“D-1” Signature of Juan Dela Cruz  To prove that the witness duly executed the
affidavit (Exh. “D”).

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

Tristan Hao
City Assistant Prosecutor

NOTICE

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.

Enrico H. Alday
Counsel of Defendant
Unit1 1, MDEC Building, Sikatuna Village, Quezon city
Roll No. 67890 / 5-2-07
IBP. No. 667899 / 12-29-07
MCLE 123141

Copy Furnished:
Tristan Hao
Assistant city prosecutor
Roll No. 67890 / 5-2-07

Page 2 of 3
IBP. No. 667899 / 12-29-07
MCLE Exempt
PTR Exempt

EXPLANATION

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

Tristan Hao
City Assistant Prosecutor

Page 3 of 3