REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

SECOND JUDICIAL REGION
BRANCH 09
Aparri, Cagayan

PEOPLE OF THE PHILIPPINES,

-versus- CRIM. CASE NO. II-14485, 14486,

and 14487 for Qualified Theft

LORETO BUMAGAT, JR.,

Accused.
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MOTION FOR THE REMARKING OF EXHIBITS

The People, through the undersigned Private Prosecutor under

the direct control and supervision of the Public Prosecutor, unto this
Honorable Court respectfully states:

1. On 27 February 2019, the undersigned Private Prosecutor

moved to correct the markings of the exhibits to be consistent with the
Judicial Affidavits of Mr. Rodel P. Cariaga, Mr. Richard Pascua and
subsequent affidavits to be filed. This Honorable Court, however,
directed the Private Prosecutor to file a motion in writing to correct the
markings.

2. Thus, it is hereby respectfully prayed that the markings of

the foregoing documents be remarked on the record of this Honorable
Court, as follows:

1
 Previously To be marked as Description
Marked as Exhibit
Exhibit
“B” “A” Amended Articles of
Incorporation of Easy Bio
Philippines, Inc.
“A” “B” Secretary’s Certificate of
Rodel P. Cariaga dated 25
January 2019
“D” “C” Letter Addressed to C.V.
Azarcon Mini Balut dated
13 November 2015
“H” “D” Letter Addressed to
Bienvenido Villaruz dated
31 March 2016
“E” “E” Sales Invoice No. 34293
amounting to P121,800.00
“F” “F” Delivery Receipt No.
010784
“J” “G” BDO Deposit Slips
“L” “H” Demand Letter Addressed
to Mr. Bumagat dated 22
June 2016
“M” “I” Demand Letter Addressed
to Mr. Bumagat dated 19
February 2018
“K” “J” Written Statement of
Richard Pascua
“G” “K” Sinumpaang Salaysay of
Ms. Cristina V. Azarcon
dated 16 February 2016
“H” “L” Sinumpaang Salaysay of
Mr. Bienvenido Villaruz
dated 31 March 2016
“N-1 to N-6” “M-1 to M-6” Official Receipt Nos.
014663, 012976,
014065,014661, 014815 and
014623.

3. Since the parties have already stipulated on the

employment and resignation of herein accused, undersigned counsel,
now moves for the non-presentation of the document described as

2
Notice of Personnel Action of Mr. Bumagat dated 27 March 2015,
previously marked as Exhibit “C.”

PRAYER

WHEREFORE, it is respectfully prayed that the remarking of the

foregoing documents be done on the record of the Honorable Court.

Respectfully submitted.

Aparri, Cagayan, 28 February 2019

Private Prosecutor

By:

With my conformity:

HON. PUBLIC PROSECUTOR

Copy Furnished:

PUBLIC ATTORNEY’S OFFICE

Aparri, Cagayan