Republic of the Philippines

TWELFTH JUDICIAL REGION

REGIONAL TRIAL COURT
Branch 14
Cotabato City

HEIRS OF DATU MAMADRA CIVIL CASE NO. 819

MASTURA,
Plaintiffs, FOR: DECLARATION
OF NULLITY OF TRANSFER
CERTIFICATES OF TITLE, ETC.

-versus-

HEIRS OF THE LATE MARIANO

TIRONA AND ESCOLASTICA G.
TIRONA,
Defendants.
x…………………………………………….x

MANIFESTATION AND MOTION

WITH FORMAL OFFER OF DOCUMENTARY EVIDENCE
FOR DEFENDANTS

COMES NOW, DEFENDANTS, through counsel and to this

Honorable Court respectfully states:

BY WAY OF MANIFESTATION

1. Last 17 February 2020, Defendants’ counsel submitted the name of

the last witness for the Defendants after the other witness, one Pedro
Linggen did not testify as expected and resulted to his Judicial
Affidavit being expunged from the records.

2. Accordingly, the Honorable Court issued an Order in open court

directing Defendants’ counsel to present, for the last time, their

Page 1 of 194
 intended witness in the morning of next Monday which is 24
February 2020.

3. Oddly, Pedro Linggen has disowned his Judicial Affidavit. Whatever

material consideration or reason which moved this witness to act
strangely when he casually denied his Sinumpaang Salaysay
Panghukoman, is one thing we are no longer interested to discern
and which we do not wish further to speculate on.

4. The oddities, however, did not stop with Mr. Linggen.

5. The witness scheduled to testify on Monday suddenly conditioned his

availability to testify only after he is given considerable time to sought
the counsel and advise first from the Mayor. As relayed to the
Defendants, the intended witness for March 24, 2020 is excusing
himself for the said scheduled hearing because he wished to seek the
blessing and approval of the Mayor of Sultan Kudarat.

6. The witness appears to be making trivial excuses for him not to testify
anytime soon. It is the assessment of Defendants’ counsels, especially
Atty. Ruben Platon that the intended witness appears hesitant to
testify making as excuse his intention to consult and seek advise first
from the Honorable Mayor of Sultan Kudarat after which he will be
scheduled to testify.

7. In view of this development, Defendants are no longer keen to wait

indefinitely for the Witness’ availability and Defendants do not wish
to make further imposition with the time of the Honorable Court.

8. Hence, Defendants lone witness is MR. DIONISIO TIRONA and

there will be no additional witness to be further presented.

Page 2 of 194
 BY WAY OF MOTION

Request for additional

markings of exhibits.

9. In view of the non-availability of the two corroborative witnesses on a

very short notice, Defendants request that in addition to Exhibits 1, 2,
and 3 which were asked to be marked in the last hearing, Defendants
likewise request at this time that the Judicial Affidavit and the
signature thereat of the primary, albeit lone, witness for the
Defendants, MR. DIONISIO TIRONA be additionally be marked as
EXHIBITS 4 and 4-a.

10.Gleaned from the records, both Exhibits 4 and 4a were previously

presented, identified and confirmed by the Affiant in open court and
under oath.

Request for a fifteen-day period

from today to submit Defendants’
Memorandum.

11. Also, Defendants are asking the Honorable Court for a period of 15
days from today to allow the Defendants to submit a
Memorandum/Position Paper.

12.Plaintiffs if they so wish, may submit their own Memorandum

simultaneously and within the same fifteen-day period.

13.Thus, Defendants respectfully move that the case be deemed

submitted for Decision upon the lapse of the period asked within
which the parties shall simultaneously submit their corresponding
Memoranda or as soon as both Parties have submitted their
respective Memoranda, whichever comes earlier.

Page 3 of 194
 FORMAL OFFER OF DOCUMENTARY
EXHIBITS AND EVIDENCE

14.DEFENDANTS most respectfully offers the following documentary

evidence and exhibits for the above titled case, to wit:

EXHIBITS DESCRIPTION PURPOSE/S

1 SURVEY PLAN To correlate and

2 enhance the
3 Testimony of
4 Defendants’ witness
5 in his Judicial Affidavit
6 OR NO.
7 OR NO.
8
9
10 JUDICIAL AFFIDAVIT

4-1

SIGNATURE OF MR.

DIONISIO TIRONA

Aforesaid exhibits are all being offered to prove that the cause of
action and claim against the Heirs of Tirona by Plaintiffs are not true and
have no basis in fact and in law.

Page 4 of 194
 WHEREFORE, premises considered, it is most respectfully prayed to
this Honorable Court that the foregoing documentary exhibits, along with
the testimonies given by the Defendants’ witnesses, BE ADMITTED for
which each and all said exhibits were formally offered and submitted and,
ultimately, for the purpose of disproving the claims of the Plaintiffs and in
support of the defenses set forth in the Defendants’ Answer to the
Complaint.

RESPECTFULLY SUBMITTED at Makati City, Philippines for

Cotabato City, Philippines this 21st day of February 2020

BAYAUA, BAYAUA-ESCORPESO, RAMOS AND ASSOCIATES

Third Floor, Gonzales Building
1888 Orense St., Guadalope Nuevo
Makati City, Philippines
Counsel for the Defendants

For the Firm:

__________________________________
HAROLD A. RAMOS

Page 5 of 194
Sinumpaang-Salaysay PANGHUKOMAN of Ms. Princess C. Atienza

Killing To prove that the witness and the Defendants have been paying the real roperty taxes over Lot

To corroborate the testimony of the first witness;

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.

“4-1” Signature of Ms. Princess C. Atienza To prove that the witness duly executed the affidavit
(Exh. “B”).

“5” Judicial Affidavit of MR. DIONISIO TIRONA To testify as the primary witness for the
Defendants;

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.

“5-1” Signature of Mr. DIONISIO TIRONA To prove that the witness duly executed the affidavit
(Exh. “C”).

“D” Judicial Affidavit of To prove the performance of his duty as First Responder and
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.

“D-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the affidavit
(Exh. “D”).

Page 6 of 194
“E” Letter Endorsement to the Office of the Provincial Prosecutor/Police Report To provide the
court information pertaining to the commission of the crime of murder by the accused.

“E-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the Letter
Endorsement/Police Report (Exh. “E”).

“F” Pinagsamang Sinumpaang-Salaysay of PO2 David P. Nepomuceno and Mr. Jerry Pascua To
correlate the testimony in the Judicial Affidavit of the second witness.

“F-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the
affidavit (Exh. “F”).

“G” Crime scene picture of the body of the victim To provide the court information as to the
physical condition of the victim.

“H”

“F-1” Medical Necropsy and Toxicology To submit to the court information of the cause
of death of the accused

To corroborate the testimony of the first witness;

To correlate the report with the commission of the crime.

“F-2” Picture of dead Maria Labo To support the proof of the death of the
accused.

“G-1” Crime Scene picture of the kitchen 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 the Cauldron To prove the existence of one of 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 all being offered to prove that the cause of action and claim against the
Heirs of Tirona by Plaintiffs are not true and have no basis in fact and in law.

WHEREFORE, premises considered, it is most respectfully prayed to this Honorable Court that
the foregoing documentary exhibits, along with the testimonies given by the Defendants’ witnesses, BE
ADMITTED for which each and all said exhibits were formally offered and submitted and, ultimately, for
the purpose of disproving the claims of the Plaintiffs and in support of the defenses set forth in the
Defendants’ Answer to the Complaint.

Makati City.

August 11, 2014

Page 7 of 194
 BIAG NI LAM-ANG

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.

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

Page 8 of 194
 City Assistant Prosecutor

Republic of the Philippines

TWELFTH JUDICIAL REGION

REGIONAL TRIAL COURT

Branch 14

Cotabato City

HEIRS OF DATU MAMADRA

MASTURA,

Plaintiffs,

For: MURDER

-versus-

JOEY CRUZ y VALENCIANO,

Accused.

x--------------------------------------------------------------------------------------x

FORMAL OFFER OF DOCUMENTARY EVIDENCE

P 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

“1” SURVEY PLAN To correlate the testimony in the Judicial Affidavit (Exh. “C” for Plaintiff).

“2” OR To prove that the witness and the Defendants have been paying the real roperty taxes
over Lot.

“3”

Page 9 of 194
4 OR

Sinumpaang-Salaysay PANGHUKOMAN of Ms. Princess C. Atienza

Killing To prove that the witness and the Defendants have been paying the real roperty taxes over Lot

To corroborate the testimony of the first witness;

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

Page 10 of 194
To establish the circumstances surrounding the commission of the crime.

“4-1” Signature of Ms. Princess C. Atienza To prove that the witness duly executed the affidavit
(Exh. “B”).

“5” Judicial Affidavit of MR. DIONISIO TIRONA To testify as the primary witness for the
Defendants;

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.

“5-1” Signature of Mr. DIONISIO TIRONA To prove that the witness duly executed the affidavit
(Exh. “C”).

“D” Judicial Affidavit of To prove the performance of his duty as First Responder and
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.

“D-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the affidavit
(Exh. “D”).

“E” Letter Endorsement to the Office of the Provincial Prosecutor/Police Report To provide the
court information pertaining to the commission of the crime of murder by the accused.

“E-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the Letter
Endorsement/Police Report (Exh. “E”).

“F” Pinagsamang Sinumpaang-Salaysay of PO2 David P. Nepomuceno and Mr. Jerry Pascua To
correlate the testimony in the Judicial Affidavit of the second witness.

“F-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the
affidavit (Exh. “F”).

“G” Crime scene picture of the body of the victim To provide the court information as to the
physical condition of the victim.

“H”

“F-1” Medical Necropsy and Toxicology To submit to the court information of the cause
of death of the accused

To corroborate the testimony of the first witness;

To correlate the report with the commission of the crime.

“F-2” Picture of dead Maria Labo To support the proof of the death of the
accused.

“G-1” Crime Scene picture of the kitchen 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 the Cauldron To prove the existence of one of 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;

Page 11 of 194
To corroborate the testimony of the two witnesses presented.

Aforesaid exhibits are all being offered to prove that the cause of action and claim against the
Heirs of Tirona by Plaintiffs are not true and have no basis in fact and in law.

WHEREFORE, premises considered, it is most respectfully prayed to this Honorable Court that
the foregoing documentary exhibits, along with the testimonies given by the Defendants’ witnesses, BE
ADMITTED for which each and all said exhibits were formally offered and submitted and, ultimately, for
the purpose of disproving the claims of the Plaintiffs and in support of the defenses set forth in the
Defendants’ Answer to the Complaint.

Makati City.

August 11, 2014

BIAG NI LAM-ANG

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.

BIAG NI LAM-ANG

City Assistant Prosecutor

Page 12 of 194
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

Republic of the Philippines

TWELFTH JUDICIAL REGION

REGIONAL TRIAL COURT

Branch 14

Cotabato City

HEIRS OF DATU MAMADRA

MASTURA,

Plaintiffs,

For: MURDER

-versus-

JOEY CRUZ y VALENCIANO,

Accused.

x--------------------------------------------------------------------------------------x

FORMAL OFFER OF DOCUMENTARY EVIDENCE

Page 13 of 194
P 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

“1” SURVEY PLAN To correlate the testimony in the Judicial Affidavit (Exh. “C” for Plaintiff).

“2” OR To prove that the witness and the Defendants have been paying the real roperty taxes
over Lot.

“3”

4 OR

Sinumpaang-Salaysay PANGHUKOMAN of Ms. Princess C. Atienza

Killing To prove that the witness and the Defendants have been paying the real roperty taxes over Lot

Page 14 of 194
To corroborate the testimony of the first witness;

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.

“4-1” Signature of Ms. Princess C. Atienza To prove that the witness duly executed the affidavit
(Exh. “B”).

“5” Judicial Affidavit of MR. DIONISIO TIRONA To testify as the primary witness for the
Defendants;

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.

“5-1” Signature of Mr. DIONISIO TIRONA To prove that the witness duly executed the affidavit
(Exh. “C”).

“D” Judicial Affidavit of To prove the performance of his duty as First Responder and
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.

“D-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the affidavit
(Exh. “D”).

“E” Letter Endorsement to the Office of the Provincial Prosecutor/Police Report To provide the
court information pertaining to the commission of the crime of murder by the accused.

“E-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the Letter
Endorsement/Police Report (Exh. “E”).

“F” Pinagsamang Sinumpaang-Salaysay of PO2 David P. Nepomuceno and Mr. Jerry Pascua To
correlate the testimony in the Judicial Affidavit of the second witness.

“F-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the
affidavit (Exh. “F”).

“G” Crime scene picture of the body of the victim To provide the court information as to the
physical condition of the victim.

Page 15 of 194
“H”

“F-1” Medical Necropsy and Toxicology To submit to the court information of the cause
of death of the accused

To corroborate the testimony of the first witness;

To correlate the report with the commission of the crime.

“F-2” Picture of dead Maria Labo To support the proof of the death of the
accused.

“G-1” Crime Scene picture of the kitchen 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 the Cauldron To prove the existence of one of 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 all being offered to prove that the cause of action and claim against the
Heirs of Tirona by Plaintiffs are not true and have no basis in fact and in law.

WHEREFORE, premises considered, it is most respectfully prayed to this Honorable Court that
the foregoing documentary exhibits, along with the testimonies given by the Defendants’ witnesses, BE
ADMITTED for which each and all said exhibits were formally offered and submitted and, ultimately, for
the purpose of disproving the claims of the Plaintiffs and in support of the defenses set forth in the
Defendants’ Answer to the Complaint.

Makati City.

August 11, 2014

BIAG NI LAM-ANG

City Assistant Prosecutor

NOTICE

Page 16 of 194
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

Republic of the Philippines

TWELFTH JUDICIAL REGION

REGIONAL TRIAL COURT

Branch 14

Cotabato City

Page 17 of 194
HEIRS OF DATU MAMADRA

MASTURA,

Plaintiffs,

For: MURDER

-versus-

JOEY CRUZ y VALENCIANO,

Accused.

x--------------------------------------------------------------------------------------x

FORMAL OFFER OF DOCUMENTARY EVIDENCE

P 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

“1” SURVEY PLAN To correlate the testimony in the Judicial Affidavit (Exh. “C” for Plaintiff).

“2” OR To prove that the witness and the Defendants have been paying the real roperty taxes
over Lot.

“3”

4 OR

Page 18 of 194
Sinumpaang-Salaysay PANGHUKOMAN of Ms. Princess C. Atienza

Killing To prove that the witness and the Defendants have been paying the real roperty taxes over Lot

To corroborate the testimony of the first witness;

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.

“4-1” Signature of Ms. Princess C. Atienza To prove that the witness duly executed the affidavit
(Exh. “B”).

“5” Judicial Affidavit of MR. DIONISIO TIRONA To testify as the primary witness for the
Defendants;

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 19 of 194
“5-1” Signature of Mr. DIONISIO TIRONA To prove that the witness duly executed the affidavit
(Exh. “C”).

“D” Judicial Affidavit of To prove the performance of his duty as First Responder and
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.

“D-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the affidavit
(Exh. “D”).

“E” Letter Endorsement to the Office of the Provincial Prosecutor/Police Report To provide the
court information pertaining to the commission of the crime of murder by the accused.

“E-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the Letter
Endorsement/Police Report (Exh. “E”).

“F” Pinagsamang Sinumpaang-Salaysay of PO2 David P. Nepomuceno and Mr. Jerry Pascua To
correlate the testimony in the Judicial Affidavit of the second witness.

“F-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the
affidavit (Exh. “F”).

“G” Crime scene picture of the body of the victim To provide the court information as to the
physical condition of the victim.

“H”

“F-1” Medical Necropsy and Toxicology To submit to the court information of the cause
of death of the accused

To corroborate the testimony of the first witness;

To correlate the report with the commission of the crime.

“F-2” Picture of dead Maria Labo To support the proof of the death of the
accused.

“G-1” Crime Scene picture of the kitchen 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 the Cauldron To prove the existence of one of 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 all being offered to prove that the cause of action and claim against the
Heirs of Tirona by Plaintiffs are not true and have no basis in fact and in law.

WHEREFORE, premises considered, it is most respectfully prayed to this Honorable Court that
the foregoing documentary exhibits, along with the testimonies given by the Defendants’ witnesses, BE

Page 20 of 194
ADMITTED for which each and all said exhibits were formally offered and submitted and, ultimately, for
the purpose of disproving the claims of the Plaintiffs and in support of the defenses set forth in the
Defendants’ Answer to the Complaint.

Makati City.

August 11, 2014

BIAG NI LAM-ANG

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.

BIAG NI LAM-ANG

City Assistant Prosecutor

Copy Furnished:

Counsel for the Accused

Page 21 of 194
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

Republic of the Philippines

TWELFTH JUDICIAL REGION

REGIONAL TRIAL COURT

Branch 14

Cotabato City

HEIRS OF DATU MAMADRA

MASTURA,

Plaintiffs,

For: MURDER

-versus-

JOEY CRUZ y VALENCIANO,

Accused.

x--------------------------------------------------------------------------------------x

FORMAL OFFER OF DOCUMENTARY EVIDENCE

P 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

“1” SURVEY PLAN To correlate the testimony in the Judicial Affidavit (Exh. “C” for Plaintiff).

Page 22 of 194
“2” OR To prove that the witness and the Defendants have been paying the real roperty taxes
over Lot.

“3”

4 OR

Sinumpaang-Salaysay PANGHUKOMAN of Ms. Princess C. Atienza

Killing To prove that the witness and the Defendants have been paying the real roperty taxes over Lot

Page 23 of 194
To corroborate the testimony of the first witness;

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.

“4-1” Signature of Ms. Princess C. Atienza To prove that the witness duly executed the affidavit
(Exh. “B”).

“5” Judicial Affidavit of MR. DIONISIO TIRONA To testify as the primary witness for the
Defendants;

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.

“5-1” Signature of Mr. DIONISIO TIRONA To prove that the witness duly executed the affidavit
(Exh. “C”).

“D” Judicial Affidavit of To prove the performance of his duty as First Responder and
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.

“D-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the affidavit
(Exh. “D”).

“E” Letter Endorsement to the Office of the Provincial Prosecutor/Police Report To provide the
court information pertaining to the commission of the crime of murder by the accused.

“E-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the Letter
Endorsement/Police Report (Exh. “E”).

“F” Pinagsamang Sinumpaang-Salaysay of PO2 David P. Nepomuceno and Mr. Jerry Pascua To
correlate the testimony in the Judicial Affidavit of the second witness.

“F-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the
affidavit (Exh. “F”).

“G” Crime scene picture of the body of the victim To provide the court information as to the
physical condition of the victim.

“H”

“F-1” Medical Necropsy and Toxicology To submit to the court information of the cause
of death of the accused

To corroborate the testimony of the first witness;

To correlate the report with the commission of the crime.

“F-2” Picture of dead Maria Labo To support the proof of the death of the
accused.

Page 24 of 194
“G-1” Crime Scene picture of the kitchen 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 the Cauldron To prove the existence of one of 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 all being offered to prove that the cause of action and claim against the
Heirs of Tirona by Plaintiffs are not true and have no basis in fact and in law.

WHEREFORE, premises considered, it is most respectfully prayed to this Honorable Court that
the foregoing documentary exhibits, along with the testimonies given by the Defendants’ witnesses, BE
ADMITTED for which each and all said exhibits were formally offered and submitted and, ultimately, for
the purpose of disproving the claims of the Plaintiffs and in support of the defenses set forth in the
Defendants’ Answer to the Complaint.

Makati City.

August 11, 2014

BIAG NI LAM-ANG

City Assistant Prosecutor

NOTICE

The Hon. Clerk of Court

RTC Branch ___ Makati City

Page 25 of 194
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

Republic of the Philippines

TWELFTH JUDICIAL REGION

REGIONAL TRIAL COURT

Branch 14

Cotabato City

HEIRS OF DATU MAMADRA

MASTURA,

Plaintiffs,

Page 26 of 194
 For: MURDER

-versus-

JOEY CRUZ y VALENCIANO,

Accused.

x--------------------------------------------------------------------------------------x

FORMAL OFFER OF DOCUMENTARY EVIDENCE

P 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

“1” SURVEY PLAN To correlate the testimony in the Judicial Affidavit (Exh. “C” for Plaintiff).

“2” OR To prove that the witness and the Defendants have been paying the real roperty taxes
over Lot.

“3”

4 OR

Page 27 of 194
Sinumpaang-Salaysay PANGHUKOMAN of Ms. Princess C. Atienza

Killing To prove that the witness and the Defendants have been paying the real roperty taxes over Lot

To corroborate the testimony of the first witness;

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.

“4-1” Signature of Ms. Princess C. Atienza To prove that the witness duly executed the affidavit
(Exh. “B”).

“5” Judicial Affidavit of MR. DIONISIO TIRONA To testify as the primary witness for the
Defendants;

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.

“5-1” Signature of Mr. DIONISIO TIRONA To prove that the witness duly executed the affidavit
(Exh. “C”).

“D” Judicial Affidavit of To prove the performance of his duty as First Responder and
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.

Page 28 of 194
“D-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the affidavit
(Exh. “D”).

“E” Letter Endorsement to the Office of the Provincial Prosecutor/Police Report To provide the
court information pertaining to the commission of the crime of murder by the accused.

“E-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the Letter
Endorsement/Police Report (Exh. “E”).

“F” Pinagsamang Sinumpaang-Salaysay of PO2 David P. Nepomuceno and Mr. Jerry Pascua To
correlate the testimony in the Judicial Affidavit of the second witness.

“F-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the
affidavit (Exh. “F”).

“G” Crime scene picture of the body of the victim To provide the court information as to the
physical condition of the victim.

“H”

“F-1” Medical Necropsy and Toxicology To submit to the court information of the cause
of death of the accused

To corroborate the testimony of the first witness;

To correlate the report with the commission of the crime.

“F-2” Picture of dead Maria Labo To support the proof of the death of the
accused.

“G-1” Crime Scene picture of the kitchen 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 the Cauldron To prove the existence of one of 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 all being offered to prove that the cause of action and claim against the
Heirs of Tirona by Plaintiffs are not true and have no basis in fact and in law.

WHEREFORE, premises considered, it is most respectfully prayed to this Honorable Court that
the foregoing documentary exhibits, along with the testimonies given by the Defendants’ witnesses, BE
ADMITTED for which each and all said exhibits were formally offered and submitted and, ultimately, for
the purpose of disproving the claims of the Plaintiffs and in support of the defenses set forth in the
Defendants’ Answer to the Complaint.

Makati City.

Page 29 of 194
 August 11, 2014

BIAG NI LAM-ANG

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.

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.

Page 30 of 194
 BIAG NI LAM-ANG

City Assistant Prosecutor

Republic of the Philippines

TWELFTH JUDICIAL REGION

REGIONAL TRIAL COURT

Branch 14

Cotabato City

HEIRS OF DATU MAMADRA

MASTURA,

Plaintiffs,

For: MURDER

-versus-

JOEY CRUZ y VALENCIANO,

Accused.

x--------------------------------------------------------------------------------------x

FORMAL OFFER OF DOCUMENTARY EVIDENCE

P 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

“1” SURVEY PLAN To correlate the testimony in the Judicial Affidavit (Exh. “C” for Plaintiff).

“2” OR To prove that the witness and the Defendants have been paying the real roperty taxes
over Lot.

“3”

Page 31 of 194
4 OR

Sinumpaang-Salaysay PANGHUKOMAN of Ms. Princess C. Atienza

Killing To prove that the witness and the Defendants have been paying the real roperty taxes over Lot

To corroborate the testimony of the first witness;

To testify to the truth of the affidavit executed;

Page 32 of 194
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.

“4-1” Signature of Ms. Princess C. Atienza To prove that the witness duly executed the affidavit
(Exh. “B”).

“5” Judicial Affidavit of MR. DIONISIO TIRONA To testify as the primary witness for the
Defendants;

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.

“5-1” Signature of Mr. DIONISIO TIRONA To prove that the witness duly executed the affidavit
(Exh. “C”).

“D” Judicial Affidavit of To prove the performance of his duty as First Responder and
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.

“D-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the affidavit
(Exh. “D”).

“E” Letter Endorsement to the Office of the Provincial Prosecutor/Police Report To provide the
court information pertaining to the commission of the crime of murder by the accused.

“E-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the Letter
Endorsement/Police Report (Exh. “E”).

“F” Pinagsamang Sinumpaang-Salaysay of PO2 David P. Nepomuceno and Mr. Jerry Pascua To
correlate the testimony in the Judicial Affidavit of the second witness.

“F-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the
affidavit (Exh. “F”).

“G” Crime scene picture of the body of the victim To provide the court information as to the
physical condition of the victim.

“H”

“F-1” Medical Necropsy and Toxicology To submit to the court information of the cause
of death of the accused

To corroborate the testimony of the first witness;

To correlate the report with the commission of the crime.

“F-2” Picture of dead Maria Labo To support the proof of the death of the
accused.

“G-1” Crime Scene picture of the kitchen 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 the Cauldron To prove the existence of one of the
instruments/tools used in killing the victim;

To corroborate the testimony of the two witnesses presented.

Page 33 of 194
“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 all being offered to prove that the cause of action and claim against the
Heirs of Tirona by Plaintiffs are not true and have no basis in fact and in law.

WHEREFORE, premises considered, it is most respectfully prayed to this Honorable Court that
the foregoing documentary exhibits, along with the testimonies given by the Defendants’ witnesses, BE
ADMITTED for which each and all said exhibits were formally offered and submitted and, ultimately, for
the purpose of disproving the claims of the Plaintiffs and in support of the defenses set forth in the
Defendants’ Answer to the Complaint.

Makati City.

August 11, 2014

BIAG NI LAM-ANG

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.

Page 34 of 194
 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

Republic of the Philippines

TWELFTH JUDICIAL REGION

REGIONAL TRIAL COURT

Branch 14

Cotabato City

HEIRS OF DATU MAMADRA

MASTURA,

Plaintiffs,

For: MURDER

-versus-

JOEY CRUZ y VALENCIANO,

Accused.

x--------------------------------------------------------------------------------------x

Page 35 of 194
FORMAL OFFER OF DOCUMENTARY EVIDENCE

P 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

“1” SURVEY PLAN To correlate the testimony in the Judicial Affidavit (Exh. “C” for Plaintiff).

“2” OR To prove that the witness and the Defendants have been paying the real roperty taxes
over Lot.

“3”

4 OR

Sinumpaang-Salaysay PANGHUKOMAN of Ms. Princess C. Atienza

Page 36 of 194
Killing To prove that the witness and the Defendants have been paying the real roperty taxes over Lot

To corroborate the testimony of the first witness;

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.

“4-1” Signature of Ms. Princess C. Atienza To prove that the witness duly executed the affidavit
(Exh. “B”).

“5” Judicial Affidavit of MR. DIONISIO TIRONA To testify as the primary witness for the
Defendants;

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.

“5-1” Signature of Mr. DIONISIO TIRONA To prove that the witness duly executed the affidavit
(Exh. “C”).

“D” Judicial Affidavit of To prove the performance of his duty as First Responder and
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.

“D-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the affidavit
(Exh. “D”).

“E” Letter Endorsement to the Office of the Provincial Prosecutor/Police Report To provide the
court information pertaining to the commission of the crime of murder by the accused.

“E-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the Letter
Endorsement/Police Report (Exh. “E”).

“F” Pinagsamang Sinumpaang-Salaysay of PO2 David P. Nepomuceno and Mr. Jerry Pascua To
correlate the testimony in the Judicial Affidavit of the second witness.

Page 37 of 194
“F-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the
affidavit (Exh. “F”).

“G” Crime scene picture of the body of the victim To provide the court information as to the
physical condition of the victim.

“H”

“F-1” Medical Necropsy and Toxicology To submit to the court information of the cause
of death of the accused

To corroborate the testimony of the first witness;

To correlate the report with the commission of the crime.

“F-2” Picture of dead Maria Labo To support the proof of the death of the
accused.

“G-1” Crime Scene picture of the kitchen 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 the Cauldron To prove the existence of one of 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 all being offered to prove that the cause of action and claim against the
Heirs of Tirona by Plaintiffs are not true and have no basis in fact and in law.

WHEREFORE, premises considered, it is most respectfully prayed to this Honorable Court that
the foregoing documentary exhibits, along with the testimonies given by the Defendants’ witnesses, BE
ADMITTED for which each and all said exhibits were formally offered and submitted and, ultimately, for
the purpose of disproving the claims of the Plaintiffs and in support of the defenses set forth in the
Defendants’ Answer to the Complaint.

Makati City.

August 11, 2014

BIAG NI LAM-ANG

City Assistant Prosecutor

Page 38 of 194
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.

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

Republic of the Philippines

TWELFTH JUDICIAL REGION

Page 39 of 194
REGIONAL TRIAL COURT

Branch 14

Cotabato City

HEIRS OF DATU MAMADRA

MASTURA,

Plaintiffs,

For: MURDER

-versus-

JOEY CRUZ y VALENCIANO,

Accused.

x--------------------------------------------------------------------------------------x

FORMAL OFFER OF DOCUMENTARY EVIDENCE

P 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

“1” SURVEY PLAN To correlate the testimony in the Judicial Affidavit (Exh. “C” for Plaintiff).

“2” OR To prove that the witness and the Defendants have been paying the real roperty taxes
over Lot.

“3”

Page 40 of 194
4 OR

Sinumpaang-Salaysay PANGHUKOMAN of Ms. Princess C. Atienza

Killing To prove that the witness and the Defendants have been paying the real roperty taxes over Lot

To corroborate the testimony of the first witness;

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.

“4-1” Signature of Ms. Princess C. Atienza To prove that the witness duly executed the affidavit
(Exh. “B”).

“5” Judicial Affidavit of MR. DIONISIO TIRONA To testify as the primary witness for the
Defendants;

Page 41 of 194
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.

“5-1” Signature of Mr. DIONISIO TIRONA To prove that the witness duly executed the affidavit
(Exh. “C”).

“D” Judicial Affidavit of To prove the performance of his duty as First Responder and
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.

“D-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the affidavit
(Exh. “D”).

“E” Letter Endorsement to the Office of the Provincial Prosecutor/Police Report To provide the
court information pertaining to the commission of the crime of murder by the accused.

“E-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the Letter
Endorsement/Police Report (Exh. “E”).

“F” Pinagsamang Sinumpaang-Salaysay of PO2 David P. Nepomuceno and Mr. Jerry Pascua To
correlate the testimony in the Judicial Affidavit of the second witness.

“F-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the
affidavit (Exh. “F”).

“G” Crime scene picture of the body of the victim To provide the court information as to the
physical condition of the victim.

“H”

“F-1” Medical Necropsy and Toxicology To submit to the court information of the cause
of death of the accused

To corroborate the testimony of the first witness;

To correlate the report with the commission of the crime.

“F-2” Picture of dead Maria Labo To support the proof of the death of the
accused.

“G-1” Crime Scene picture of the kitchen 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 the Cauldron To prove the existence of one of 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.

Page 42 of 194
 Aforesaid exhibits are all being offered to prove that the cause of action and claim against the
Heirs of Tirona by Plaintiffs are not true and have no basis in fact and in law.

WHEREFORE, premises considered, it is most respectfully prayed to this Honorable Court that
the foregoing documentary exhibits, along with the testimonies given by the Defendants’ witnesses, BE
ADMITTED for which each and all said exhibits were formally offered and submitted and, ultimately, for
the purpose of disproving the claims of the Plaintiffs and in support of the defenses set forth in the
Defendants’ Answer to the Complaint.

Makati City.

August 11, 2014

BIAG NI LAM-ANG

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.

BIAG NI LAM-ANG

City Assistant Prosecutor

Copy Furnished:

Page 43 of 194
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

Republic of the Philippines

TWELFTH JUDICIAL REGION

REGIONAL TRIAL COURT

Branch 14

Cotabato City

HEIRS OF DATU MAMADRA

MASTURA,

Plaintiffs,

For: MURDER

-versus-

JOEY CRUZ y VALENCIANO,

Accused.

x--------------------------------------------------------------------------------------x

FORMAL OFFER OF DOCUMENTARY EVIDENCE

P by the undersigned counsel and unto this Honorable Court, most respectfully offers the following
documentary and exhibits for the above titled case, to wit:

Page 44 of 194
EXHIBITS DESCRIPTION PURPOSE/S

“1” SURVEY PLAN To correlate the testimony in the Judicial Affidavit (Exh. “C” for Plaintiff).

“2” OR To prove that the witness and the Defendants have been paying the real roperty taxes
over Lot.

“3”

4 OR

Sinumpaang-Salaysay PANGHUKOMAN of Ms. Princess C. Atienza

Killing To prove that the witness and the Defendants have been paying the real roperty taxes over Lot

Page 45 of 194
To corroborate the testimony of the first witness;

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.

“4-1” Signature of Ms. Princess C. Atienza To prove that the witness duly executed the affidavit
(Exh. “B”).

“5” Judicial Affidavit of MR. DIONISIO TIRONA To testify as the primary witness for the
Defendants;

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.

“5-1” Signature of Mr. DIONISIO TIRONA To prove that the witness duly executed the affidavit
(Exh. “C”).

“D” Judicial Affidavit of To prove the performance of his duty as First Responder and
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.

“D-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the affidavit
(Exh. “D”).

“E” Letter Endorsement to the Office of the Provincial Prosecutor/Police Report To provide the
court information pertaining to the commission of the crime of murder by the accused.

“E-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the Letter
Endorsement/Police Report (Exh. “E”).

“F” Pinagsamang Sinumpaang-Salaysay of PO2 David P. Nepomuceno and Mr. Jerry Pascua To
correlate the testimony in the Judicial Affidavit of the second witness.

“F-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the
affidavit (Exh. “F”).

“G” Crime scene picture of the body of the victim To provide the court information as to the
physical condition of the victim.

“H”

“F-1” Medical Necropsy and Toxicology To submit to the court information of the cause
of death of the accused

To corroborate the testimony of the first witness;

Page 46 of 194
To correlate the report with the commission of the crime.

“F-2” Picture of dead Maria Labo To support the proof of the death of the
accused.

“G-1” Crime Scene picture of the kitchen 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 the Cauldron To prove the existence of one of 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 all being offered to prove that the cause of action and claim against the
Heirs of Tirona by Plaintiffs are not true and have no basis in fact and in law.

WHEREFORE, premises considered, it is most respectfully prayed to this Honorable Court that
the foregoing documentary exhibits, along with the testimonies given by the Defendants’ witnesses, BE
ADMITTED for which each and all said exhibits were formally offered and submitted and, ultimately, for
the purpose of disproving the claims of the Plaintiffs and in support of the defenses set forth in the
Defendants’ Answer to the Complaint.

Makati City.

August 11, 2014

BIAG NI LAM-ANG

City Assistant Prosecutor

NOTICE

The Hon. Clerk of Court

Page 47 of 194
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

Republic of the Philippines

TWELFTH JUDICIAL REGION

REGIONAL TRIAL COURT

Branch 14

Cotabato City

HEIRS OF DATU MAMADRA

MASTURA,

Page 48 of 194
 Plaintiffs,

For: MURDER

-versus-

JOEY CRUZ y VALENCIANO,

Accused.

x--------------------------------------------------------------------------------------x

FORMAL OFFER OF DOCUMENTARY EVIDENCE

P 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

“1” SURVEY PLAN To correlate the testimony in the Judicial Affidavit (Exh. “C” for Plaintiff).

“2” OR To prove that the witness and the Defendants have been paying the real roperty taxes
over Lot.

“3”

4 OR

Page 49 of 194
Sinumpaang-Salaysay PANGHUKOMAN of Ms. Princess C. Atienza

Killing To prove that the witness and the Defendants have been paying the real roperty taxes over Lot

To corroborate the testimony of the first witness;

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.

“4-1” Signature of Ms. Princess C. Atienza To prove that the witness duly executed the affidavit
(Exh. “B”).

“5” Judicial Affidavit of MR. DIONISIO TIRONA To testify as the primary witness for the
Defendants;

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.

“5-1” Signature of Mr. DIONISIO TIRONA To prove that the witness duly executed the affidavit
(Exh. “C”).

“D” Judicial Affidavit of To prove the performance of his duty as First Responder and
Investigator within the scope of his duty and regular performance of duty;

Page 50 of 194
To testify to the truth of the affidavit executed;

To identify the victim and the accused.

“D-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the affidavit
(Exh. “D”).

“E” Letter Endorsement to the Office of the Provincial Prosecutor/Police Report To provide the
court information pertaining to the commission of the crime of murder by the accused.

“E-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the Letter
Endorsement/Police Report (Exh. “E”).

“F” Pinagsamang Sinumpaang-Salaysay of PO2 David P. Nepomuceno and Mr. Jerry Pascua To
correlate the testimony in the Judicial Affidavit of the second witness.

“F-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the
affidavit (Exh. “F”).

“G” Crime scene picture of the body of the victim To provide the court information as to the
physical condition of the victim.

“H”

“F-1” Medical Necropsy and Toxicology To submit to the court information of the cause
of death of the accused

To corroborate the testimony of the first witness;

To correlate the report with the commission of the crime.

“F-2” Picture of dead Maria Labo To support the proof of the death of the
accused.

“G-1” Crime Scene picture of the kitchen 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 the Cauldron To prove the existence of one of 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 all being offered to prove that the cause of action and claim against the
Heirs of Tirona by Plaintiffs are not true and have no basis in fact and in law.

WHEREFORE, premises considered, it is most respectfully prayed to this Honorable Court that
the foregoing documentary exhibits, along with the testimonies given by the Defendants’ witnesses, BE
ADMITTED for which each and all said exhibits were formally offered and submitted and, ultimately, for
the purpose of disproving the claims of the Plaintiffs and in support of the defenses set forth in the
Defendants’ Answer to the Complaint.

Page 51 of 194
Makati City.

August 11, 2014

BIAG NI LAM-ANG

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.

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.

Page 52 of 194
 BIAG NI LAM-ANG

City Assistant Prosecutor

Republic of the Philippines

TWELFTH JUDICIAL REGION

REGIONAL TRIAL COURT

Branch 14

Cotabato City

HEIRS OF DATU MAMADRA

MASTURA,

Plaintiffs,

For: MURDER

-versus-

JOEY CRUZ y VALENCIANO,

Accused.

x--------------------------------------------------------------------------------------x

FORMAL OFFER OF DOCUMENTARY EVIDENCE

P 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

“1” SURVEY PLAN To correlate the testimony in the Judicial Affidavit (Exh. “C” for Plaintiff).

“2” OR To prove that the witness and the Defendants have been paying the real roperty taxes
over Lot.

“3”

Page 53 of 194
4 OR

Sinumpaang-Salaysay PANGHUKOMAN of Ms. Princess C. Atienza

Killing To prove that the witness and the Defendants have been paying the real roperty taxes over Lot

Page 54 of 194
To corroborate the testimony of the first witness;

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.

“4-1” Signature of Ms. Princess C. Atienza To prove that the witness duly executed the affidavit
(Exh. “B”).

“5” Judicial Affidavit of MR. DIONISIO TIRONA To testify as the primary witness for the
Defendants;

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.

“5-1” Signature of Mr. DIONISIO TIRONA To prove that the witness duly executed the affidavit
(Exh. “C”).

“D” Judicial Affidavit of To prove the performance of his duty as First Responder and
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.

“D-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the affidavit
(Exh. “D”).

“E” Letter Endorsement to the Office of the Provincial Prosecutor/Police Report To provide the
court information pertaining to the commission of the crime of murder by the accused.

“E-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the Letter
Endorsement/Police Report (Exh. “E”).

“F” Pinagsamang Sinumpaang-Salaysay of PO2 David P. Nepomuceno and Mr. Jerry Pascua To
correlate the testimony in the Judicial Affidavit of the second witness.

“F-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the
affidavit (Exh. “F”).

“G” Crime scene picture of the body of the victim To provide the court information as to the
physical condition of the victim.

“H”

“F-1” Medical Necropsy and Toxicology To submit to the court information of the cause
of death of the accused

To corroborate the testimony of the first witness;

To correlate the report with the commission of the crime.

“F-2” Picture of dead Maria Labo To support the proof of the death of the
accused.

“G-1” Crime Scene picture of the kitchen To provide the court information as to
the place where the crime was committed

To corroborate the testimony of the two witnesses presented.

Page 55 of 194
“G-2” Crime scene picture of the Cauldron To prove the existence of one of 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 all being offered to prove that the cause of action and claim against the
Heirs of Tirona by Plaintiffs are not true and have no basis in fact and in law.

WHEREFORE, premises considered, it is most respectfully prayed to this Honorable Court that
the foregoing documentary exhibits, along with the testimonies given by the Defendants’ witnesses, BE
ADMITTED for which each and all said exhibits were formally offered and submitted and, ultimately, for
the purpose of disproving the claims of the Plaintiffs and in support of the defenses set forth in the
Defendants’ Answer to the Complaint.

Makati City.

August 11, 2014

BIAG NI LAM-ANG

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.

Page 56 of 194
 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

Republic of the Philippines

TWELFTH JUDICIAL REGION

REGIONAL TRIAL COURT

Branch 14

Cotabato City

HEIRS OF DATU MAMADRA

MASTURA,

Plaintiffs,

For: MURDER

-versus-

Page 57 of 194
JOEY CRUZ y VALENCIANO,

Accused.

x--------------------------------------------------------------------------------------x

FORMAL OFFER OF DOCUMENTARY EVIDENCE

P 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

“1” SURVEY PLAN To correlate the testimony in the Judicial Affidavit (Exh. “C” for Plaintiff).

“2” OR To prove that the witness and the Defendants have been paying the real roperty taxes
over Lot.

“3”

4 OR

Page 58 of 194
Sinumpaang-Salaysay PANGHUKOMAN of Ms. Princess C. Atienza

Killing To prove that the witness and the Defendants have been paying the real roperty taxes over Lot

To corroborate the testimony of the first witness;

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.

“4-1” Signature of Ms. Princess C. Atienza To prove that the witness duly executed the affidavit
(Exh. “B”).

“5” Judicial Affidavit of MR. DIONISIO TIRONA To testify as the primary witness for the
Defendants;

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.

“5-1” Signature of Mr. DIONISIO TIRONA To prove that the witness duly executed the affidavit
(Exh. “C”).

“D” Judicial Affidavit of To prove the performance of his duty as First Responder and
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.

“D-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the affidavit
(Exh. “D”).

“E” Letter Endorsement to the Office of the Provincial Prosecutor/Police Report To provide the
court information pertaining to the commission of the crime of murder by the accused.

“E-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the Letter
Endorsement/Police Report (Exh. “E”).

Page 59 of 194
“F” Pinagsamang Sinumpaang-Salaysay of PO2 David P. Nepomuceno and Mr. Jerry Pascua To
correlate the testimony in the Judicial Affidavit of the second witness.

“F-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the
affidavit (Exh. “F”).

“G” Crime scene picture of the body of the victim To provide the court information as to the
physical condition of the victim.

“H”

“F-1” Medical Necropsy and Toxicology To submit to the court information of the cause
of death of the accused

To corroborate the testimony of the first witness;

To correlate the report with the commission of the crime.

“F-2” Picture of dead Maria Labo To support the proof of the death of the
accused.

“G-1” Crime Scene picture of the kitchen 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 the Cauldron To prove the existence of one of 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 all being offered to prove that the cause of action and claim against the
Heirs of Tirona by Plaintiffs are not true and have no basis in fact and in law.

WHEREFORE, premises considered, it is most respectfully prayed to this Honorable Court that
the foregoing documentary exhibits, along with the testimonies given by the Defendants’ witnesses, BE
ADMITTED for which each and all said exhibits were formally offered and submitted and, ultimately, for
the purpose of disproving the claims of the Plaintiffs and in support of the defenses set forth in the
Defendants’ Answer to the Complaint.

Makati City.

August 11, 2014

BIAG NI LAM-ANG

Page 60 of 194
 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.

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

Republic of the Philippines

Page 61 of 194
TWELFTH JUDICIAL REGION

REGIONAL TRIAL COURT

Branch 14

Cotabato City

HEIRS OF DATU MAMADRA

MASTURA,

Plaintiffs,

For: MURDER

-versus-

JOEY CRUZ y VALENCIANO,

Accused.

x--------------------------------------------------------------------------------------x

FORMAL OFFER OF DOCUMENTARY EVIDENCE

P 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

“1” SURVEY PLAN To correlate the testimony in the Judicial Affidavit (Exh. “C” for Plaintiff).

“2” OR To prove that the witness and the Defendants have been paying the real roperty taxes
over Lot.

“3”

Page 62 of 194
4 OR

Sinumpaang-Salaysay PANGHUKOMAN of Ms. Princess C. Atienza

Killing To prove that the witness and the Defendants have been paying the real roperty taxes over Lot

To corroborate the testimony of the first witness;

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.

“4-1” Signature of Ms. Princess C. Atienza To prove that the witness duly executed the affidavit
(Exh. “B”).

Page 63 of 194
“5” Judicial Affidavit of MR. DIONISIO TIRONA To testify as the primary witness for the
Defendants;

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.

“5-1” Signature of Mr. DIONISIO TIRONA To prove that the witness duly executed the affidavit
(Exh. “C”).

“D” Judicial Affidavit of To prove the performance of his duty as First Responder and
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.

“D-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the affidavit
(Exh. “D”).

“E” Letter Endorsement to the Office of the Provincial Prosecutor/Police Report To provide the
court information pertaining to the commission of the crime of murder by the accused.

“E-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the Letter
Endorsement/Police Report (Exh. “E”).

“F” Pinagsamang Sinumpaang-Salaysay of PO2 David P. Nepomuceno and Mr. Jerry Pascua To
correlate the testimony in the Judicial Affidavit of the second witness.

“F-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the
affidavit (Exh. “F”).

“G” Crime scene picture of the body of the victim To provide the court information as to the
physical condition of the victim.

“H”

“F-1” Medical Necropsy and Toxicology To submit to the court information of the cause
of death of the accused

To corroborate the testimony of the first witness;

To correlate the report with the commission of the crime.

“F-2” Picture of dead Maria Labo To support the proof of the death of the
accused.

“G-1” Crime Scene picture of the kitchen 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 the Cauldron To prove the existence of one of 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.

Page 64 of 194
 Aforesaid exhibits are all being offered to prove that the cause of action and claim against the
Heirs of Tirona by Plaintiffs are not true and have no basis in fact and in law.

WHEREFORE, premises considered, it is most respectfully prayed to this Honorable Court that
the foregoing documentary exhibits, along with the testimonies given by the Defendants’ witnesses, BE
ADMITTED for which each and all said exhibits were formally offered and submitted and, ultimately, for
the purpose of disproving the claims of the Plaintiffs and in support of the defenses set forth in the
Defendants’ Answer to the Complaint.

Makati City.

August 11, 2014

BIAG NI LAM-ANG

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.

BIAG NI LAM-ANG

City Assistant Prosecutor

Page 65 of 194
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

Republic of the Philippines

TWELFTH JUDICIAL REGION

REGIONAL TRIAL COURT

Branch 14

Cotabato City

HEIRS OF DATU MAMADRA

MASTURA,

Plaintiffs,

For: MURDER

-versus-

JOEY CRUZ y VALENCIANO,

Accused.

x--------------------------------------------------------------------------------------x

FORMAL OFFER OF DOCUMENTARY EVIDENCE

Page 66 of 194
P 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

“1” SURVEY PLAN To correlate the testimony in the Judicial Affidavit (Exh. “C” for Plaintiff).

“2” OR To prove that the witness and the Defendants have been paying the real roperty taxes
over Lot.

“3”

4 OR

Sinumpaang-Salaysay PANGHUKOMAN of Ms. Princess C. Atienza

Killing To prove that the witness and the Defendants have been paying the real roperty taxes over Lot

Page 67 of 194
To corroborate the testimony of the first witness;

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.

“4-1” Signature of Ms. Princess C. Atienza To prove that the witness duly executed the affidavit
(Exh. “B”).

“5” Judicial Affidavit of MR. DIONISIO TIRONA To testify as the primary witness for the
Defendants;

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.

“5-1” Signature of Mr. DIONISIO TIRONA To prove that the witness duly executed the affidavit
(Exh. “C”).

“D” Judicial Affidavit of To prove the performance of his duty as First Responder and
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.

“D-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the affidavit
(Exh. “D”).

“E” Letter Endorsement to the Office of the Provincial Prosecutor/Police Report To provide the
court information pertaining to the commission of the crime of murder by the accused.

“E-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the Letter
Endorsement/Police Report (Exh. “E”).

“F” Pinagsamang Sinumpaang-Salaysay of PO2 David P. Nepomuceno and Mr. Jerry Pascua To
correlate the testimony in the Judicial Affidavit of the second witness.

“F-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the
affidavit (Exh. “F”).

“G” Crime scene picture of the body of the victim To provide the court information as to the
physical condition of the victim.

“H”

Page 68 of 194
“F-1” Medical Necropsy and Toxicology To submit to the court information of the cause
of death of the accused

To corroborate the testimony of the first witness;

To correlate the report with the commission of the crime.

“F-2” Picture of dead Maria Labo To support the proof of the death of the
accused.

“G-1” Crime Scene picture of the kitchen 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 the Cauldron To prove the existence of one of 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 all being offered to prove that the cause of action and claim against the
Heirs of Tirona by Plaintiffs are not true and have no basis in fact and in law.

WHEREFORE, premises considered, it is most respectfully prayed to this Honorable Court that
the foregoing documentary exhibits, along with the testimonies given by the Defendants’ witnesses, BE
ADMITTED for which each and all said exhibits were formally offered and submitted and, ultimately, for
the purpose of disproving the claims of the Plaintiffs and in support of the defenses set forth in the
Defendants’ Answer to the Complaint.

Makati City.

August 11, 2014

BIAG NI LAM-ANG

City Assistant Prosecutor

NOTICE

Page 69 of 194
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

Republic of the Philippines

TWELFTH JUDICIAL REGION

REGIONAL TRIAL COURT

Branch 14

Cotabato City

Page 70 of 194
HEIRS OF DATU MAMADRA

MASTURA,

Plaintiffs,

For: MURDER

-versus-

JOEY CRUZ y VALENCIANO,

Accused.

x--------------------------------------------------------------------------------------x

FORMAL OFFER OF DOCUMENTARY EVIDENCE

P 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

“1” SURVEY PLAN To correlate the testimony in the Judicial Affidavit (Exh. “C” for Plaintiff).

“2” OR To prove that the witness and the Defendants have been paying the real roperty taxes
over Lot.

“3”

4 OR

Page 71 of 194
Sinumpaang-Salaysay PANGHUKOMAN of Ms. Princess C. Atienza

Killing To prove that the witness and the Defendants have been paying the real roperty taxes over Lot

To corroborate the testimony of the first witness;

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.

“4-1” Signature of Ms. Princess C. Atienza To prove that the witness duly executed the affidavit
(Exh. “B”).

“5” Judicial Affidavit of MR. DIONISIO TIRONA To testify as the primary witness for the
Defendants;

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 72 of 194
“5-1” Signature of Mr. DIONISIO TIRONA To prove that the witness duly executed the affidavit
(Exh. “C”).

“D” Judicial Affidavit of To prove the performance of his duty as First Responder and
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.

“D-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the affidavit
(Exh. “D”).

“E” Letter Endorsement to the Office of the Provincial Prosecutor/Police Report To provide the
court information pertaining to the commission of the crime of murder by the accused.

“E-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the Letter
Endorsement/Police Report (Exh. “E”).

“F” Pinagsamang Sinumpaang-Salaysay of PO2 David P. Nepomuceno and Mr. Jerry Pascua To
correlate the testimony in the Judicial Affidavit of the second witness.

“F-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the
affidavit (Exh. “F”).

“G” Crime scene picture of the body of the victim To provide the court information as to the
physical condition of the victim.

“H”

“F-1” Medical Necropsy and Toxicology To submit to the court information of the cause
of death of the accused

To corroborate the testimony of the first witness;

To correlate the report with the commission of the crime.

“F-2” Picture of dead Maria Labo To support the proof of the death of the
accused.

“G-1” Crime Scene picture of the kitchen 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 the Cauldron To prove the existence of one of 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 all being offered to prove that the cause of action and claim against the
Heirs of Tirona by Plaintiffs are not true and have no basis in fact and in law.

WHEREFORE, premises considered, it is most respectfully prayed to this Honorable Court that
the foregoing documentary exhibits, along with the testimonies given by the Defendants’ witnesses, BE

Page 73 of 194
ADMITTED for which each and all said exhibits were formally offered and submitted and, ultimately, for
the purpose of disproving the claims of the Plaintiffs and in support of the defenses set forth in the
Defendants’ Answer to the Complaint.

Makati City.

August 11, 2014

BIAG NI LAM-ANG

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.

BIAG NI LAM-ANG

City Assistant Prosecutor

Copy Furnished:

Counsel for the Accused

Page 74 of 194
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

Republic of the Philippines

TWELFTH JUDICIAL REGION

REGIONAL TRIAL COURT

Branch 14

Cotabato City

HEIRS OF DATU MAMADRA

MASTURA,

Plaintiffs,

For: MURDER

-versus-

JOEY CRUZ y VALENCIANO,

Accused.

x--------------------------------------------------------------------------------------x

FORMAL OFFER OF DOCUMENTARY EVIDENCE

P 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

“1” SURVEY PLAN To correlate the testimony in the Judicial Affidavit (Exh. “C” for Plaintiff).

Page 75 of 194
“2” OR To prove that the witness and the Defendants have been paying the real roperty taxes
over Lot.

“3”

4 OR

Sinumpaang-Salaysay PANGHUKOMAN of Ms. Princess C. Atienza

Killing To prove that the witness and the Defendants have been paying the real roperty taxes over Lot

Page 76 of 194
To corroborate the testimony of the first witness;

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.

“4-1” Signature of Ms. Princess C. Atienza To prove that the witness duly executed the affidavit
(Exh. “B”).

“5” Judicial Affidavit of MR. DIONISIO TIRONA To testify as the primary witness for the
Defendants;

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.

“5-1” Signature of Mr. DIONISIO TIRONA To prove that the witness duly executed the affidavit
(Exh. “C”).

“D” Judicial Affidavit of To prove the performance of his duty as First Responder and
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.

“D-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the affidavit
(Exh. “D”).

“E” Letter Endorsement to the Office of the Provincial Prosecutor/Police Report To provide the
court information pertaining to the commission of the crime of murder by the accused.

“E-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the Letter
Endorsement/Police Report (Exh. “E”).

“F” Pinagsamang Sinumpaang-Salaysay of PO2 David P. Nepomuceno and Mr. Jerry Pascua To
correlate the testimony in the Judicial Affidavit of the second witness.

“F-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the
affidavit (Exh. “F”).

“G” Crime scene picture of the body of the victim To provide the court information as to the
physical condition of the victim.

“H”

“F-1” Medical Necropsy and Toxicology To submit to the court information of the cause
of death of the accused

To corroborate the testimony of the first witness;

To correlate the report with the commission of the crime.

“F-2” Picture of dead Maria Labo To support the proof of the death of the
accused.

Page 77 of 194
“G-1” Crime Scene picture of the kitchen 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 the Cauldron To prove the existence of one of 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 all being offered to prove that the cause of action and claim against the
Heirs of Tirona by Plaintiffs are not true and have no basis in fact and in law.

WHEREFORE, premises considered, it is most respectfully prayed to this Honorable Court that
the foregoing documentary exhibits, along with the testimonies given by the Defendants’ witnesses, BE
ADMITTED for which each and all said exhibits were formally offered and submitted and, ultimately, for
the purpose of disproving the claims of the Plaintiffs and in support of the defenses set forth in the
Defendants’ Answer to the Complaint.

Makati City.

August 11, 2014

BIAG NI LAM-ANG

City Assistant Prosecutor

NOTICE

The Hon. Clerk of Court

RTC Branch ___ Makati City

Page 78 of 194
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

Republic of the Philippines

TWELFTH JUDICIAL REGION

REGIONAL TRIAL COURT

Branch 14

Cotabato City

HEIRS OF DATU MAMADRA

MASTURA,

Plaintiffs,

Page 79 of 194
 For: MURDER

-versus-

JOEY CRUZ y VALENCIANO,

Accused.

x--------------------------------------------------------------------------------------x

FORMAL OFFER OF DOCUMENTARY EVIDENCE

P 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

“1” SURVEY PLAN To correlate the testimony in the Judicial Affidavit (Exh. “C” for Plaintiff).

“2” OR To prove that the witness and the Defendants have been paying the real roperty taxes
over Lot.

“3”

4 OR

Page 80 of 194
Sinumpaang-Salaysay PANGHUKOMAN of Ms. Princess C. Atienza

Killing To prove that the witness and the Defendants have been paying the real roperty taxes over Lot

To corroborate the testimony of the first witness;

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.

“4-1” Signature of Ms. Princess C. Atienza To prove that the witness duly executed the affidavit
(Exh. “B”).

“5” Judicial Affidavit of MR. DIONISIO TIRONA To testify as the primary witness for the
Defendants;

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.

“5-1” Signature of Mr. DIONISIO TIRONA To prove that the witness duly executed the affidavit
(Exh. “C”).

“D” Judicial Affidavit of To prove the performance of his duty as First Responder and
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.

Page 81 of 194
“D-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the affidavit
(Exh. “D”).

“E” Letter Endorsement to the Office of the Provincial Prosecutor/Police Report To provide the
court information pertaining to the commission of the crime of murder by the accused.

“E-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the Letter
Endorsement/Police Report (Exh. “E”).

“F” Pinagsamang Sinumpaang-Salaysay of PO2 David P. Nepomuceno and Mr. Jerry Pascua To
correlate the testimony in the Judicial Affidavit of the second witness.

“F-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the
affidavit (Exh. “F”).

“G” Crime scene picture of the body of the victim To provide the court information as to the
physical condition of the victim.

“H”

“F-1” Medical Necropsy and Toxicology To submit to the court information of the cause
of death of the accused

To corroborate the testimony of the first witness;

To correlate the report with the commission of the crime.

“F-2” Picture of dead Maria Labo To support the proof of the death of the
accused.

“G-1” Crime Scene picture of the kitchen 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 the Cauldron To prove the existence of one of 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 all being offered to prove that the cause of action and claim against the
Heirs of Tirona by Plaintiffs are not true and have no basis in fact and in law.

WHEREFORE, premises considered, it is most respectfully prayed to this Honorable Court that
the foregoing documentary exhibits, along with the testimonies given by the Defendants’ witnesses, BE
ADMITTED for which each and all said exhibits were formally offered and submitted and, ultimately, for
the purpose of disproving the claims of the Plaintiffs and in support of the defenses set forth in the
Defendants’ Answer to the Complaint.

Makati City.

Page 82 of 194
 August 11, 2014

BIAG NI LAM-ANG

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.

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.

Page 83 of 194
 BIAG NI LAM-ANG

City Assistant Prosecutor

Republic of the Philippines

TWELFTH JUDICIAL REGION

REGIONAL TRIAL COURT

Branch 14

Cotabato City

HEIRS OF DATU MAMADRA

MASTURA,

Plaintiffs,

For: MURDER

-versus-

JOEY CRUZ y VALENCIANO,

Accused.

x--------------------------------------------------------------------------------------x

FORMAL OFFER OF DOCUMENTARY EVIDENCE

P 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

“1” SURVEY PLAN To correlate the testimony in the Judicial Affidavit (Exh. “C” for Plaintiff).

“2” OR To prove that the witness and the Defendants have been paying the real roperty taxes
over Lot.

“3”

Page 84 of 194
4 OR

Sinumpaang-Salaysay PANGHUKOMAN of Ms. Princess C. Atienza

Killing To prove that the witness and the Defendants have been paying the real roperty taxes over Lot

To corroborate the testimony of the first witness;

To testify to the truth of the affidavit executed;

Page 85 of 194
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.

“4-1” Signature of Ms. Princess C. Atienza To prove that the witness duly executed the affidavit
(Exh. “B”).

“5” Judicial Affidavit of MR. DIONISIO TIRONA To testify as the primary witness for the
Defendants;

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.

“5-1” Signature of Mr. DIONISIO TIRONA To prove that the witness duly executed the affidavit
(Exh. “C”).

“D” Judicial Affidavit of To prove the performance of his duty as First Responder and
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.

“D-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the affidavit
(Exh. “D”).

“E” Letter Endorsement to the Office of the Provincial Prosecutor/Police Report To provide the
court information pertaining to the commission of the crime of murder by the accused.

“E-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the Letter
Endorsement/Police Report (Exh. “E”).

“F” Pinagsamang Sinumpaang-Salaysay of PO2 David P. Nepomuceno and Mr. Jerry Pascua To
correlate the testimony in the Judicial Affidavit of the second witness.

“F-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the
affidavit (Exh. “F”).

“G” Crime scene picture of the body of the victim To provide the court information as to the
physical condition of the victim.

“H”

“F-1” Medical Necropsy and Toxicology To submit to the court information of the cause
of death of the accused

To corroborate the testimony of the first witness;

To correlate the report with the commission of the crime.

“F-2” Picture of dead Maria Labo To support the proof of the death of the
accused.

“G-1” Crime Scene picture of the kitchen 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 the Cauldron To prove the existence of one of the
instruments/tools used in killing the victim;

To corroborate the testimony of the two witnesses presented.

Page 86 of 194
“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 all being offered to prove that the cause of action and claim against the
Heirs of Tirona by Plaintiffs are not true and have no basis in fact and in law.

WHEREFORE, premises considered, it is most respectfully prayed to this Honorable Court that
the foregoing documentary exhibits, along with the testimonies given by the Defendants’ witnesses, BE
ADMITTED for which each and all said exhibits were formally offered and submitted and, ultimately, for
the purpose of disproving the claims of the Plaintiffs and in support of the defenses set forth in the
Defendants’ Answer to the Complaint.

Makati City.

August 11, 2014

BIAG NI LAM-ANG

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.

Page 87 of 194
 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

Republic of the Philippines

TWELFTH JUDICIAL REGION

REGIONAL TRIAL COURT

Branch 14

Cotabato City

HEIRS OF DATU MAMADRA

MASTURA,

Plaintiffs,

For: MURDER

-versus-

JOEY CRUZ y VALENCIANO,

Accused.

x--------------------------------------------------------------------------------------x

Page 88 of 194
FORMAL OFFER OF DOCUMENTARY EVIDENCE

P 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

“1” SURVEY PLAN To correlate the testimony in the Judicial Affidavit (Exh. “C” for Plaintiff).

“2” OR To prove that the witness and the Defendants have been paying the real roperty taxes
over Lot.

“3”

4 OR

Sinumpaang-Salaysay PANGHUKOMAN of Ms. Princess C. Atienza

Page 89 of 194
Killing To prove that the witness and the Defendants have been paying the real roperty taxes over Lot

To corroborate the testimony of the first witness;

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.

“4-1” Signature of Ms. Princess C. Atienza To prove that the witness duly executed the affidavit
(Exh. “B”).

“5” Judicial Affidavit of MR. DIONISIO TIRONA To testify as the primary witness for the
Defendants;

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.

“5-1” Signature of Mr. DIONISIO TIRONA To prove that the witness duly executed the affidavit
(Exh. “C”).

“D” Judicial Affidavit of To prove the performance of his duty as First Responder and
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.

“D-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the affidavit
(Exh. “D”).

“E” Letter Endorsement to the Office of the Provincial Prosecutor/Police Report To provide the
court information pertaining to the commission of the crime of murder by the accused.

“E-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the Letter
Endorsement/Police Report (Exh. “E”).

“F” Pinagsamang Sinumpaang-Salaysay of PO2 David P. Nepomuceno and Mr. Jerry Pascua To
correlate the testimony in the Judicial Affidavit of the second witness.

Page 90 of 194
“F-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the
affidavit (Exh. “F”).

“G” Crime scene picture of the body of the victim To provide the court information as to the
physical condition of the victim.

“H”

“F-1” Medical Necropsy and Toxicology To submit to the court information of the cause
of death of the accused

To corroborate the testimony of the first witness;

To correlate the report with the commission of the crime.

“F-2” Picture of dead Maria Labo To support the proof of the death of the
accused.

“G-1” Crime Scene picture of the kitchen 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 the Cauldron To prove the existence of one of 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 all being offered to prove that the cause of action and claim against the
Heirs of Tirona by Plaintiffs are not true and have no basis in fact and in law.

WHEREFORE, premises considered, it is most respectfully prayed to this Honorable Court that
the foregoing documentary exhibits, along with the testimonies given by the Defendants’ witnesses, BE
ADMITTED for which each and all said exhibits were formally offered and submitted and, ultimately, for
the purpose of disproving the claims of the Plaintiffs and in support of the defenses set forth in the
Defendants’ Answer to the Complaint.

Makati City.

August 11, 2014

BIAG NI LAM-ANG

City Assistant Prosecutor

Page 91 of 194
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.

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

Republic of the Philippines

TWELFTH JUDICIAL REGION

Page 92 of 194
REGIONAL TRIAL COURT

Branch 14

Cotabato City

HEIRS OF DATU MAMADRA

MASTURA,

Plaintiffs,

For: MURDER

-versus-

JOEY CRUZ y VALENCIANO,

Accused.

x--------------------------------------------------------------------------------------x

FORMAL OFFER OF DOCUMENTARY EVIDENCE

P 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

“1” SURVEY PLAN To correlate the testimony in the Judicial Affidavit (Exh. “C” for Plaintiff).

“2” OR To prove that the witness and the Defendants have been paying the real roperty taxes
over Lot.

“3”

Page 93 of 194
4 OR

Sinumpaang-Salaysay PANGHUKOMAN of Ms. Princess C. Atienza

Killing To prove that the witness and the Defendants have been paying the real roperty taxes over Lot

To corroborate the testimony of the first witness;

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.

“4-1” Signature of Ms. Princess C. Atienza To prove that the witness duly executed the affidavit
(Exh. “B”).

“5” Judicial Affidavit of MR. DIONISIO TIRONA To testify as the primary witness for the
Defendants;

Page 94 of 194
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.

“5-1” Signature of Mr. DIONISIO TIRONA To prove that the witness duly executed the affidavit
(Exh. “C”).

“D” Judicial Affidavit of To prove the performance of his duty as First Responder and
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.

“D-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the affidavit
(Exh. “D”).

“E” Letter Endorsement to the Office of the Provincial Prosecutor/Police Report To provide the
court information pertaining to the commission of the crime of murder by the accused.

“E-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the Letter
Endorsement/Police Report (Exh. “E”).

“F” Pinagsamang Sinumpaang-Salaysay of PO2 David P. Nepomuceno and Mr. Jerry Pascua To
correlate the testimony in the Judicial Affidavit of the second witness.

“F-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the
affidavit (Exh. “F”).

“G” Crime scene picture of the body of the victim To provide the court information as to the
physical condition of the victim.

“H”

“F-1” Medical Necropsy and Toxicology To submit to the court information of the cause
of death of the accused

To corroborate the testimony of the first witness;

To correlate the report with the commission of the crime.

“F-2” Picture of dead Maria Labo To support the proof of the death of the
accused.

“G-1” Crime Scene picture of the kitchen 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 the Cauldron To prove the existence of one of 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.

Page 95 of 194
 Aforesaid exhibits are all being offered to prove that the cause of action and claim against the
Heirs of Tirona by Plaintiffs are not true and have no basis in fact and in law.

WHEREFORE, premises considered, it is most respectfully prayed to this Honorable Court that
the foregoing documentary exhibits, along with the testimonies given by the Defendants’ witnesses, BE
ADMITTED for which each and all said exhibits were formally offered and submitted and, ultimately, for
the purpose of disproving the claims of the Plaintiffs and in support of the defenses set forth in the
Defendants’ Answer to the Complaint.

Makati City.

August 11, 2014

BIAG NI LAM-ANG

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.

BIAG NI LAM-ANG

City Assistant Prosecutor

Copy Furnished:

Page 96 of 194
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

Republic of the Philippines

TWELFTH JUDICIAL REGION

REGIONAL TRIAL COURT

Branch 14

Cotabato City

HEIRS OF DATU MAMADRA

MASTURA,

Plaintiffs,

For: MURDER

-versus-

JOEY CRUZ y VALENCIANO,

Accused.

x--------------------------------------------------------------------------------------x

FORMAL OFFER OF DOCUMENTARY EVIDENCE

P by the undersigned counsel and unto this Honorable Court, most respectfully offers the following
documentary and exhibits for the above titled case, to wit:

Page 97 of 194
EXHIBITS DESCRIPTION PURPOSE/S

“1” SURVEY PLAN To correlate the testimony in the Judicial Affidavit (Exh. “C” for Plaintiff).

“2” OR To prove that the witness and the Defendants have been paying the real roperty taxes
over Lot.

“3”

4 OR

Sinumpaang-Salaysay PANGHUKOMAN of Ms. Princess C. Atienza

Killing To prove that the witness and the Defendants have been paying the real roperty taxes over Lot

Page 98 of 194
To corroborate the testimony of the first witness;

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.

“4-1” Signature of Ms. Princess C. Atienza To prove that the witness duly executed the affidavit
(Exh. “B”).

“5” Judicial Affidavit of MR. DIONISIO TIRONA To testify as the primary witness for the
Defendants;

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.

“5-1” Signature of Mr. DIONISIO TIRONA To prove that the witness duly executed the affidavit
(Exh. “C”).

“D” Judicial Affidavit of To prove the performance of his duty as First Responder and
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.

“D-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the affidavit
(Exh. “D”).

“E” Letter Endorsement to the Office of the Provincial Prosecutor/Police Report To provide the
court information pertaining to the commission of the crime of murder by the accused.

“E-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the Letter
Endorsement/Police Report (Exh. “E”).

“F” Pinagsamang Sinumpaang-Salaysay of PO2 David P. Nepomuceno and Mr. Jerry Pascua To
correlate the testimony in the Judicial Affidavit of the second witness.

“F-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the
affidavit (Exh. “F”).

“G” Crime scene picture of the body of the victim To provide the court information as to the
physical condition of the victim.

“H”

“F-1” Medical Necropsy and Toxicology To submit to the court information of the cause
of death of the accused

To corroborate the testimony of the first witness;

Page 99 of 194
To correlate the report with the commission of the crime.

“F-2” Picture of dead Maria Labo To support the proof of the death of the
accused.

“G-1” Crime Scene picture of the kitchen 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 the Cauldron To prove the existence of one of 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 all being offered to prove that the cause of action and claim against the
Heirs of Tirona by Plaintiffs are not true and have no basis in fact and in law.

WHEREFORE, premises considered, it is most respectfully prayed to this Honorable Court that
the foregoing documentary exhibits, along with the testimonies given by the Defendants’ witnesses, BE
ADMITTED for which each and all said exhibits were formally offered and submitted and, ultimately, for
the purpose of disproving the claims of the Plaintiffs and in support of the defenses set forth in the
Defendants’ Answer to the Complaint.

Makati City.

August 11, 2014

BIAG NI LAM-ANG

City Assistant Prosecutor

NOTICE

The Hon. Clerk of Court

Page 100 of 194

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

Republic of the Philippines

TWELFTH JUDICIAL REGION

REGIONAL TRIAL COURT

Branch 14

Cotabato City

HEIRS OF DATU MAMADRA

MASTURA,

Page 101 of 194

 Plaintiffs,

For: MURDER

-versus-

JOEY CRUZ y VALENCIANO,

Accused.

x--------------------------------------------------------------------------------------x

FORMAL OFFER OF DOCUMENTARY EVIDENCE

P 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

“1” SURVEY PLAN To correlate the testimony in the Judicial Affidavit (Exh. “C” for Plaintiff).

“2” OR To prove that the witness and the Defendants have been paying the real roperty taxes
over Lot.

“3”

4 OR

Page 102 of 194

Sinumpaang-Salaysay PANGHUKOMAN of Ms. Princess C. Atienza

Killing To prove that the witness and the Defendants have been paying the real roperty taxes over Lot

To corroborate the testimony of the first witness;

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.

“4-1” Signature of Ms. Princess C. Atienza To prove that the witness duly executed the affidavit
(Exh. “B”).

“5” Judicial Affidavit of MR. DIONISIO TIRONA To testify as the primary witness for the
Defendants;

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.

“5-1” Signature of Mr. DIONISIO TIRONA To prove that the witness duly executed the affidavit
(Exh. “C”).

“D” Judicial Affidavit of To prove the performance of his duty as First Responder and
Investigator within the scope of his duty and regular performance of duty;

Page 103 of 194

To testify to the truth of the affidavit executed;

To identify the victim and the accused.

“D-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the affidavit
(Exh. “D”).

“E” Letter Endorsement to the Office of the Provincial Prosecutor/Police Report To provide the
court information pertaining to the commission of the crime of murder by the accused.

“E-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the Letter
Endorsement/Police Report (Exh. “E”).

“F” Pinagsamang Sinumpaang-Salaysay of PO2 David P. Nepomuceno and Mr. Jerry Pascua To
correlate the testimony in the Judicial Affidavit of the second witness.

“F-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the
affidavit (Exh. “F”).

“G” Crime scene picture of the body of the victim To provide the court information as to the
physical condition of the victim.

“H”

“F-1” Medical Necropsy and Toxicology To submit to the court information of the cause
of death of the accused

To corroborate the testimony of the first witness;

To correlate the report with the commission of the crime.

“F-2” Picture of dead Maria Labo To support the proof of the death of the
accused.

“G-1” Crime Scene picture of the kitchen 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 the Cauldron To prove the existence of one of 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 all being offered to prove that the cause of action and claim against the
Heirs of Tirona by Plaintiffs are not true and have no basis in fact and in law.

WHEREFORE, premises considered, it is most respectfully prayed to this Honorable Court that
the foregoing documentary exhibits, along with the testimonies given by the Defendants’ witnesses, BE
ADMITTED for which each and all said exhibits were formally offered and submitted and, ultimately, for
the purpose of disproving the claims of the Plaintiffs and in support of the defenses set forth in the
Defendants’ Answer to the Complaint.

Page 104 of 194

Makati City.

August 11, 2014

BIAG NI LAM-ANG

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.

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.

Page 105 of 194

 BIAG NI LAM-ANG

City Assistant Prosecutor

Republic of the Philippines

TWELFTH JUDICIAL REGION

REGIONAL TRIAL COURT

Branch 14

Cotabato City

HEIRS OF DATU MAMADRA

MASTURA,

Plaintiffs,

For: MURDER

-versus-

JOEY CRUZ y VALENCIANO,

Accused.

x--------------------------------------------------------------------------------------x

FORMAL OFFER OF DOCUMENTARY EVIDENCE

P 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

“1” SURVEY PLAN To correlate the testimony in the Judicial Affidavit (Exh. “C” for Plaintiff).

“2” OR To prove that the witness and the Defendants have been paying the real roperty taxes
over Lot.

“3”

Page 106 of 194

4 OR

Sinumpaang-Salaysay PANGHUKOMAN of Ms. Princess C. Atienza

Killing To prove that the witness and the Defendants have been paying the real roperty taxes over Lot

Page 107 of 194

To corroborate the testimony of the first witness;

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.

“4-1” Signature of Ms. Princess C. Atienza To prove that the witness duly executed the affidavit
(Exh. “B”).

“5” Judicial Affidavit of MR. DIONISIO TIRONA To testify as the primary witness for the
Defendants;

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.

“5-1” Signature of Mr. DIONISIO TIRONA To prove that the witness duly executed the affidavit
(Exh. “C”).

“D” Judicial Affidavit of To prove the performance of his duty as First Responder and
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.

“D-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the affidavit
(Exh. “D”).

“E” Letter Endorsement to the Office of the Provincial Prosecutor/Police Report To provide the
court information pertaining to the commission of the crime of murder by the accused.

“E-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the Letter
Endorsement/Police Report (Exh. “E”).

“F” Pinagsamang Sinumpaang-Salaysay of PO2 David P. Nepomuceno and Mr. Jerry Pascua To
correlate the testimony in the Judicial Affidavit of the second witness.

“F-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the
affidavit (Exh. “F”).

“G” Crime scene picture of the body of the victim To provide the court information as to the
physical condition of the victim.

“H”

“F-1” Medical Necropsy and Toxicology To submit to the court information of the cause
of death of the accused

To corroborate the testimony of the first witness;

To correlate the report with the commission of the crime.

“F-2” Picture of dead Maria Labo To support the proof of the death of the
accused.

“G-1” Crime Scene picture of the kitchen To provide the court information as to
the place where the crime was committed

To corroborate the testimony of the two witnesses presented.

Page 108 of 194

“G-2” Crime scene picture of the Cauldron To prove the existence of one of 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 all being offered to prove that the cause of action and claim against the
Heirs of Tirona by Plaintiffs are not true and have no basis in fact and in law.

WHEREFORE, premises considered, it is most respectfully prayed to this Honorable Court that
the foregoing documentary exhibits, along with the testimonies given by the Defendants’ witnesses, BE
ADMITTED for which each and all said exhibits were formally offered and submitted and, ultimately, for
the purpose of disproving the claims of the Plaintiffs and in support of the defenses set forth in the
Defendants’ Answer to the Complaint.

Makati City.

August 11, 2014

BIAG NI LAM-ANG

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.

Page 109 of 194

 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

Republic of the Philippines

TWELFTH JUDICIAL REGION

REGIONAL TRIAL COURT

Branch 14

Cotabato City

HEIRS OF DATU MAMADRA

MASTURA,

Plaintiffs,

For: MURDER

-versus-

Page 110 of 194

JOEY CRUZ y VALENCIANO,

Accused.

x--------------------------------------------------------------------------------------x

FORMAL OFFER OF DOCUMENTARY EVIDENCE

P 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

“1” SURVEY PLAN To correlate the testimony in the Judicial Affidavit (Exh. “C” for Plaintiff).

“2” OR To prove that the witness and the Defendants have been paying the real roperty taxes
over Lot.

“3”

4 OR

Page 111 of 194

Sinumpaang-Salaysay PANGHUKOMAN of Ms. Princess C. Atienza

Killing To prove that the witness and the Defendants have been paying the real roperty taxes over Lot

To corroborate the testimony of the first witness;

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.

“4-1” Signature of Ms. Princess C. Atienza To prove that the witness duly executed the affidavit
(Exh. “B”).

“5” Judicial Affidavit of MR. DIONISIO TIRONA To testify as the primary witness for the
Defendants;

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.

“5-1” Signature of Mr. DIONISIO TIRONA To prove that the witness duly executed the affidavit
(Exh. “C”).

“D” Judicial Affidavit of To prove the performance of his duty as First Responder and
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.

“D-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the affidavit
(Exh. “D”).

“E” Letter Endorsement to the Office of the Provincial Prosecutor/Police Report To provide the
court information pertaining to the commission of the crime of murder by the accused.

“E-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the Letter
Endorsement/Police Report (Exh. “E”).

Page 112 of 194

“F” Pinagsamang Sinumpaang-Salaysay of PO2 David P. Nepomuceno and Mr. Jerry Pascua To
correlate the testimony in the Judicial Affidavit of the second witness.

“F-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the
affidavit (Exh. “F”).

“G” Crime scene picture of the body of the victim To provide the court information as to the
physical condition of the victim.

“H”

“F-1” Medical Necropsy and Toxicology To submit to the court information of the cause
of death of the accused

To corroborate the testimony of the first witness;

To correlate the report with the commission of the crime.

“F-2” Picture of dead Maria Labo To support the proof of the death of the
accused.

“G-1” Crime Scene picture of the kitchen 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 the Cauldron To prove the existence of one of 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 all being offered to prove that the cause of action and claim against the
Heirs of Tirona by Plaintiffs are not true and have no basis in fact and in law.

WHEREFORE, premises considered, it is most respectfully prayed to this Honorable Court that
the foregoing documentary exhibits, along with the testimonies given by the Defendants’ witnesses, BE
ADMITTED for which each and all said exhibits were formally offered and submitted and, ultimately, for
the purpose of disproving the claims of the Plaintiffs and in support of the defenses set forth in the
Defendants’ Answer to the Complaint.

Makati City.

August 11, 2014

BIAG NI LAM-ANG

Page 113 of 194

 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.

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

Republic of the Philippines

Page 114 of 194

TWELFTH JUDICIAL REGION

REGIONAL TRIAL COURT

Branch 14

Cotabato City

HEIRS OF DATU MAMADRA

MASTURA,

Plaintiffs,

For: MURDER

-versus-

JOEY CRUZ y VALENCIANO,

Accused.

x--------------------------------------------------------------------------------------x

FORMAL OFFER OF DOCUMENTARY EVIDENCE

P 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

“1” SURVEY PLAN To correlate the testimony in the Judicial Affidavit (Exh. “C” for Plaintiff).

“2” OR To prove that the witness and the Defendants have been paying the real roperty taxes
over Lot.

“3”

Page 115 of 194

4 OR

Sinumpaang-Salaysay PANGHUKOMAN of Ms. Princess C. Atienza

Killing To prove that the witness and the Defendants have been paying the real roperty taxes over Lot

To corroborate the testimony of the first witness;

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.

“4-1” Signature of Ms. Princess C. Atienza To prove that the witness duly executed the affidavit
(Exh. “B”).

Page 116 of 194

“5” Judicial Affidavit of MR. DIONISIO TIRONA To testify as the primary witness for the
Defendants;

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.

“5-1” Signature of Mr. DIONISIO TIRONA To prove that the witness duly executed the affidavit
(Exh. “C”).

“D” Judicial Affidavit of To prove the performance of his duty as First Responder and
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.

“D-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the affidavit
(Exh. “D”).

“E” Letter Endorsement to the Office of the Provincial Prosecutor/Police Report To provide the
court information pertaining to the commission of the crime of murder by the accused.

“E-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the Letter
Endorsement/Police Report (Exh. “E”).

“F” Pinagsamang Sinumpaang-Salaysay of PO2 David P. Nepomuceno and Mr. Jerry Pascua To
correlate the testimony in the Judicial Affidavit of the second witness.

“F-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the
affidavit (Exh. “F”).

“G” Crime scene picture of the body of the victim To provide the court information as to the
physical condition of the victim.

“H”

“F-1” Medical Necropsy and Toxicology To submit to the court information of the cause
of death of the accused

To corroborate the testimony of the first witness;

To correlate the report with the commission of the crime.

“F-2” Picture of dead Maria Labo To support the proof of the death of the
accused.

“G-1” Crime Scene picture of the kitchen 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 the Cauldron To prove the existence of one of 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.

Page 117 of 194

 Aforesaid exhibits are all being offered to prove that the cause of action and claim against the
Heirs of Tirona by Plaintiffs are not true and have no basis in fact and in law.

WHEREFORE, premises considered, it is most respectfully prayed to this Honorable Court that
the foregoing documentary exhibits, along with the testimonies given by the Defendants’ witnesses, BE
ADMITTED for which each and all said exhibits were formally offered and submitted and, ultimately, for
the purpose of disproving the claims of the Plaintiffs and in support of the defenses set forth in the
Defendants’ Answer to the Complaint.

Makati City.

August 11, 2014

BIAG NI LAM-ANG

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.

BIAG NI LAM-ANG

City Assistant Prosecutor

Page 118 of 194

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

Republic of the Philippines

TWELFTH JUDICIAL REGION

REGIONAL TRIAL COURT

Branch 14

Cotabato City

HEIRS OF DATU MAMADRA

MASTURA,

Plaintiffs,

For: MURDER

-versus-

JOEY CRUZ y VALENCIANO,

Accused.

x--------------------------------------------------------------------------------------x

FORMAL OFFER OF DOCUMENTARY EVIDENCE

Page 119 of 194

P 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

“1” SURVEY PLAN To correlate the testimony in the Judicial Affidavit (Exh. “C” for Plaintiff).

“2” OR To prove that the witness and the Defendants have been paying the real roperty taxes
over Lot.

“3”

4 OR

Sinumpaang-Salaysay PANGHUKOMAN of Ms. Princess C. Atienza

Killing To prove that the witness and the Defendants have been paying the real roperty taxes over Lot

Page 120 of 194

To corroborate the testimony of the first witness;

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.

“4-1” Signature of Ms. Princess C. Atienza To prove that the witness duly executed the affidavit
(Exh. “B”).

“5” Judicial Affidavit of MR. DIONISIO TIRONA To testify as the primary witness for the
Defendants;

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.

“5-1” Signature of Mr. DIONISIO TIRONA To prove that the witness duly executed the affidavit
(Exh. “C”).

“D” Judicial Affidavit of To prove the performance of his duty as First Responder and
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.

“D-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the affidavit
(Exh. “D”).

“E” Letter Endorsement to the Office of the Provincial Prosecutor/Police Report To provide the
court information pertaining to the commission of the crime of murder by the accused.

“E-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the Letter
Endorsement/Police Report (Exh. “E”).

“F” Pinagsamang Sinumpaang-Salaysay of PO2 David P. Nepomuceno and Mr. Jerry Pascua To
correlate the testimony in the Judicial Affidavit of the second witness.

“F-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the
affidavit (Exh. “F”).

“G” Crime scene picture of the body of the victim To provide the court information as to the
physical condition of the victim.

“H”

Page 121 of 194

“F-1” Medical Necropsy and Toxicology To submit to the court information of the cause
of death of the accused

To corroborate the testimony of the first witness;

To correlate the report with the commission of the crime.

“F-2” Picture of dead Maria Labo To support the proof of the death of the
accused.

“G-1” Crime Scene picture of the kitchen 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 the Cauldron To prove the existence of one of 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 all being offered to prove that the cause of action and claim against the
Heirs of Tirona by Plaintiffs are not true and have no basis in fact and in law.

WHEREFORE, premises considered, it is most respectfully prayed to this Honorable Court that
the foregoing documentary exhibits, along with the testimonies given by the Defendants’ witnesses, BE
ADMITTED for which each and all said exhibits were formally offered and submitted and, ultimately, for
the purpose of disproving the claims of the Plaintiffs and in support of the defenses set forth in the
Defendants’ Answer to the Complaint.

Makati City.

August 11, 2014

BIAG NI LAM-ANG

City Assistant Prosecutor

NOTICE

Page 122 of 194

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

Republic of the Philippines

TWELFTH JUDICIAL REGION

REGIONAL TRIAL COURT

Branch 14

Cotabato City

Page 123 of 194

HEIRS OF DATU MAMADRA

MASTURA,

Plaintiffs,

For: MURDER

-versus-

JOEY CRUZ y VALENCIANO,

Accused.

x--------------------------------------------------------------------------------------x

FORMAL OFFER OF DOCUMENTARY EVIDENCE

P 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

“1” SURVEY PLAN To correlate the testimony in the Judicial Affidavit (Exh. “C” for Plaintiff).

“2” OR To prove that the witness and the Defendants have been paying the real roperty taxes
over Lot.

“3”

4 OR

Page 124 of 194

Sinumpaang-Salaysay PANGHUKOMAN of Ms. Princess C. Atienza

Killing To prove that the witness and the Defendants have been paying the real roperty taxes over Lot

To corroborate the testimony of the first witness;

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.

“4-1” Signature of Ms. Princess C. Atienza To prove that the witness duly executed the affidavit
(Exh. “B”).

“5” Judicial Affidavit of MR. DIONISIO TIRONA To testify as the primary witness for the
Defendants;

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 125 of 194

“5-1” Signature of Mr. DIONISIO TIRONA To prove that the witness duly executed the affidavit
(Exh. “C”).

“D” Judicial Affidavit of To prove the performance of his duty as First Responder and
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.

“D-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the affidavit
(Exh. “D”).

“E” Letter Endorsement to the Office of the Provincial Prosecutor/Police Report To provide the
court information pertaining to the commission of the crime of murder by the accused.

“E-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the Letter
Endorsement/Police Report (Exh. “E”).

“F” Pinagsamang Sinumpaang-Salaysay of PO2 David P. Nepomuceno and Mr. Jerry Pascua To
correlate the testimony in the Judicial Affidavit of the second witness.

“F-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the
affidavit (Exh. “F”).

“G” Crime scene picture of the body of the victim To provide the court information as to the
physical condition of the victim.

“H”

“F-1” Medical Necropsy and Toxicology To submit to the court information of the cause
of death of the accused

To corroborate the testimony of the first witness;

To correlate the report with the commission of the crime.

“F-2” Picture of dead Maria Labo To support the proof of the death of the
accused.

“G-1” Crime Scene picture of the kitchen 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 the Cauldron To prove the existence of one of 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 all being offered to prove that the cause of action and claim against the
Heirs of Tirona by Plaintiffs are not true and have no basis in fact and in law.

WHEREFORE, premises considered, it is most respectfully prayed to this Honorable Court that
the foregoing documentary exhibits, along with the testimonies given by the Defendants’ witnesses, BE

Page 126 of 194

ADMITTED for which each and all said exhibits were formally offered and submitted and, ultimately, for
the purpose of disproving the claims of the Plaintiffs and in support of the defenses set forth in the
Defendants’ Answer to the Complaint.

Makati City.

August 11, 2014

BIAG NI LAM-ANG

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.

BIAG NI LAM-ANG

City Assistant Prosecutor

Copy Furnished:

Counsel for the Accused

Page 127 of 194

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

Republic of the Philippines

TWELFTH JUDICIAL REGION

REGIONAL TRIAL COURT

Branch 14

Cotabato City

HEIRS OF DATU MAMADRA

MASTURA,

Plaintiffs,

For: MURDER

-versus-

JOEY CRUZ y VALENCIANO,

Accused.

x--------------------------------------------------------------------------------------x

FORMAL OFFER OF DOCUMENTARY EVIDENCE

P 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

“1” SURVEY PLAN To correlate the testimony in the Judicial Affidavit (Exh. “C” for Plaintiff).

Page 128 of 194

“2” OR To prove that the witness and the Defendants have been paying the real roperty taxes
over Lot.

“3”

4 OR

Sinumpaang-Salaysay PANGHUKOMAN of Ms. Princess C. Atienza

Killing To prove that the witness and the Defendants have been paying the real roperty taxes over Lot

Page 129 of 194

To corroborate the testimony of the first witness;

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.

“4-1” Signature of Ms. Princess C. Atienza To prove that the witness duly executed the affidavit
(Exh. “B”).

“5” Judicial Affidavit of MR. DIONISIO TIRONA To testify as the primary witness for the
Defendants;

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.

“5-1” Signature of Mr. DIONISIO TIRONA To prove that the witness duly executed the affidavit
(Exh. “C”).

“D” Judicial Affidavit of To prove the performance of his duty as First Responder and
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.

“D-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the affidavit
(Exh. “D”).

“E” Letter Endorsement to the Office of the Provincial Prosecutor/Police Report To provide the
court information pertaining to the commission of the crime of murder by the accused.

“E-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the Letter
Endorsement/Police Report (Exh. “E”).

“F” Pinagsamang Sinumpaang-Salaysay of PO2 David P. Nepomuceno and Mr. Jerry Pascua To
correlate the testimony in the Judicial Affidavit of the second witness.

“F-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the
affidavit (Exh. “F”).

“G” Crime scene picture of the body of the victim To provide the court information as to the
physical condition of the victim.

“H”

“F-1” Medical Necropsy and Toxicology To submit to the court information of the cause
of death of the accused

To corroborate the testimony of the first witness;

To correlate the report with the commission of the crime.

“F-2” Picture of dead Maria Labo To support the proof of the death of the
accused.

Page 130 of 194

“G-1” Crime Scene picture of the kitchen 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 the Cauldron To prove the existence of one of 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 all being offered to prove that the cause of action and claim against the
Heirs of Tirona by Plaintiffs are not true and have no basis in fact and in law.

WHEREFORE, premises considered, it is most respectfully prayed to this Honorable Court that
the foregoing documentary exhibits, along with the testimonies given by the Defendants’ witnesses, BE
ADMITTED for which each and all said exhibits were formally offered and submitted and, ultimately, for
the purpose of disproving the claims of the Plaintiffs and in support of the defenses set forth in the
Defendants’ Answer to the Complaint.

Makati City.

August 11, 2014

BIAG NI LAM-ANG

City Assistant Prosecutor

NOTICE

The Hon. Clerk of Court

RTC Branch ___ Makati City

Page 131 of 194

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

Republic of the Philippines

TWELFTH JUDICIAL REGION

REGIONAL TRIAL COURT

Branch 14

Cotabato City

HEIRS OF DATU MAMADRA

MASTURA,

Plaintiffs,

Page 132 of 194

 For: MURDER

-versus-

JOEY CRUZ y VALENCIANO,

Accused.

x--------------------------------------------------------------------------------------x

FORMAL OFFER OF DOCUMENTARY EVIDENCE

P 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

“1” SURVEY PLAN To correlate the testimony in the Judicial Affidavit (Exh. “C” for Plaintiff).

“2” OR To prove that the witness and the Defendants have been paying the real roperty taxes
over Lot.

“3”

4 OR

Page 133 of 194

Sinumpaang-Salaysay PANGHUKOMAN of Ms. Princess C. Atienza

Killing To prove that the witness and the Defendants have been paying the real roperty taxes over Lot

To corroborate the testimony of the first witness;

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.

“4-1” Signature of Ms. Princess C. Atienza To prove that the witness duly executed the affidavit
(Exh. “B”).

“5” Judicial Affidavit of MR. DIONISIO TIRONA To testify as the primary witness for the
Defendants;

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.

“5-1” Signature of Mr. DIONISIO TIRONA To prove that the witness duly executed the affidavit
(Exh. “C”).

“D” Judicial Affidavit of To prove the performance of his duty as First Responder and
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.

Page 134 of 194

“D-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the affidavit
(Exh. “D”).

“E” Letter Endorsement to the Office of the Provincial Prosecutor/Police Report To provide the
court information pertaining to the commission of the crime of murder by the accused.

“E-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the Letter
Endorsement/Police Report (Exh. “E”).

“F” Pinagsamang Sinumpaang-Salaysay of PO2 David P. Nepomuceno and Mr. Jerry Pascua To
correlate the testimony in the Judicial Affidavit of the second witness.

“F-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the
affidavit (Exh. “F”).

“G” Crime scene picture of the body of the victim To provide the court information as to the
physical condition of the victim.

“H”

“F-1” Medical Necropsy and Toxicology To submit to the court information of the cause
of death of the accused

To corroborate the testimony of the first witness;

To correlate the report with the commission of the crime.

“F-2” Picture of dead Maria Labo To support the proof of the death of the
accused.

“G-1” Crime Scene picture of the kitchen 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 the Cauldron To prove the existence of one of 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 all being offered to prove that the cause of action and claim against the
Heirs of Tirona by Plaintiffs are not true and have no basis in fact and in law.

WHEREFORE, premises considered, it is most respectfully prayed to this Honorable Court that
the foregoing documentary exhibits, along with the testimonies given by the Defendants’ witnesses, BE
ADMITTED for which each and all said exhibits were formally offered and submitted and, ultimately, for
the purpose of disproving the claims of the Plaintiffs and in support of the defenses set forth in the
Defendants’ Answer to the Complaint.

Makati City.

Page 135 of 194

 August 11, 2014

BIAG NI LAM-ANG

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.

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.

Page 136 of 194

 BIAG NI LAM-ANG

City Assistant Prosecutor

Republic of the Philippines

TWELFTH JUDICIAL REGION

REGIONAL TRIAL COURT

Branch 14

Cotabato City

HEIRS OF DATU MAMADRA

MASTURA,

Plaintiffs,

For: MURDER

-versus-

JOEY CRUZ y VALENCIANO,

Accused.

x--------------------------------------------------------------------------------------x

FORMAL OFFER OF DOCUMENTARY EVIDENCE

P 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

“1” SURVEY PLAN To correlate the testimony in the Judicial Affidavit (Exh. “C” for Plaintiff).

“2” OR To prove that the witness and the Defendants have been paying the real roperty taxes
over Lot.

“3”

Page 137 of 194

4 OR

Sinumpaang-Salaysay PANGHUKOMAN of Ms. Princess C. Atienza

Killing To prove that the witness and the Defendants have been paying the real roperty taxes over Lot

To corroborate the testimony of the first witness;

To testify to the truth of the affidavit executed;

Page 138 of 194

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.

“4-1” Signature of Ms. Princess C. Atienza To prove that the witness duly executed the affidavit
(Exh. “B”).

“5” Judicial Affidavit of MR. DIONISIO TIRONA To testify as the primary witness for the
Defendants;

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.

“5-1” Signature of Mr. DIONISIO TIRONA To prove that the witness duly executed the affidavit
(Exh. “C”).

“D” Judicial Affidavit of To prove the performance of his duty as First Responder and
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.

“D-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the affidavit
(Exh. “D”).

“E” Letter Endorsement to the Office of the Provincial Prosecutor/Police Report To provide the
court information pertaining to the commission of the crime of murder by the accused.

“E-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the Letter
Endorsement/Police Report (Exh. “E”).

“F” Pinagsamang Sinumpaang-Salaysay of PO2 David P. Nepomuceno and Mr. Jerry Pascua To
correlate the testimony in the Judicial Affidavit of the second witness.

“F-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the
affidavit (Exh. “F”).

“G” Crime scene picture of the body of the victim To provide the court information as to the
physical condition of the victim.

“H”

“F-1” Medical Necropsy and Toxicology To submit to the court information of the cause
of death of the accused

To corroborate the testimony of the first witness;

To correlate the report with the commission of the crime.

“F-2” Picture of dead Maria Labo To support the proof of the death of the
accused.

“G-1” Crime Scene picture of the kitchen 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 the Cauldron To prove the existence of one of the
instruments/tools used in killing the victim;

To corroborate the testimony of the two witnesses presented.

Page 139 of 194

“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 all being offered to prove that the cause of action and claim against the
Heirs of Tirona by Plaintiffs are not true and have no basis in fact and in law.

WHEREFORE, premises considered, it is most respectfully prayed to this Honorable Court that
the foregoing documentary exhibits, along with the testimonies given by the Defendants’ witnesses, BE
ADMITTED for which each and all said exhibits were formally offered and submitted and, ultimately, for
the purpose of disproving the claims of the Plaintiffs and in support of the defenses set forth in the
Defendants’ Answer to the Complaint.

Makati City.

August 11, 2014

BIAG NI LAM-ANG

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.

Page 140 of 194

 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

Republic of the Philippines

TWELFTH JUDICIAL REGION

REGIONAL TRIAL COURT

Branch 14

Cotabato City

HEIRS OF DATU MAMADRA

MASTURA,

Plaintiffs,

For: MURDER

-versus-

JOEY CRUZ y VALENCIANO,

Accused.

x--------------------------------------------------------------------------------------x

Page 141 of 194

FORMAL OFFER OF DOCUMENTARY EVIDENCE

P 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

“1” SURVEY PLAN To correlate the testimony in the Judicial Affidavit (Exh. “C” for Plaintiff).

“2” OR To prove that the witness and the Defendants have been paying the real roperty taxes
over Lot.

“3”

4 OR

Sinumpaang-Salaysay PANGHUKOMAN of Ms. Princess C. Atienza

Page 142 of 194

Killing To prove that the witness and the Defendants have been paying the real roperty taxes over Lot

To corroborate the testimony of the first witness;

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.

“4-1” Signature of Ms. Princess C. Atienza To prove that the witness duly executed the affidavit
(Exh. “B”).

“5” Judicial Affidavit of MR. DIONISIO TIRONA To testify as the primary witness for the
Defendants;

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.

“5-1” Signature of Mr. DIONISIO TIRONA To prove that the witness duly executed the affidavit
(Exh. “C”).

“D” Judicial Affidavit of To prove the performance of his duty as First Responder and
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.

“D-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the affidavit
(Exh. “D”).

“E” Letter Endorsement to the Office of the Provincial Prosecutor/Police Report To provide the
court information pertaining to the commission of the crime of murder by the accused.

“E-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the Letter
Endorsement/Police Report (Exh. “E”).

“F” Pinagsamang Sinumpaang-Salaysay of PO2 David P. Nepomuceno and Mr. Jerry Pascua To
correlate the testimony in the Judicial Affidavit of the second witness.

Page 143 of 194

“F-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the
affidavit (Exh. “F”).

“G” Crime scene picture of the body of the victim To provide the court information as to the
physical condition of the victim.

“H”

“F-1” Medical Necropsy and Toxicology To submit to the court information of the cause
of death of the accused

To corroborate the testimony of the first witness;

To correlate the report with the commission of the crime.

“F-2” Picture of dead Maria Labo To support the proof of the death of the
accused.

“G-1” Crime Scene picture of the kitchen 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 the Cauldron To prove the existence of one of 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 all being offered to prove that the cause of action and claim against the
Heirs of Tirona by Plaintiffs are not true and have no basis in fact and in law.

WHEREFORE, premises considered, it is most respectfully prayed to this Honorable Court that
the foregoing documentary exhibits, along with the testimonies given by the Defendants’ witnesses, BE
ADMITTED for which each and all said exhibits were formally offered and submitted and, ultimately, for
the purpose of disproving the claims of the Plaintiffs and in support of the defenses set forth in the
Defendants’ Answer to the Complaint.

Makati City.

August 11, 2014

BIAG NI LAM-ANG

City Assistant Prosecutor

Page 144 of 194

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.

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

Republic of the Philippines

TWELFTH JUDICIAL REGION

Page 145 of 194

REGIONAL TRIAL COURT

Branch 14

Cotabato City

HEIRS OF DATU MAMADRA

MASTURA,

Plaintiffs,

For: MURDER

-versus-

JOEY CRUZ y VALENCIANO,

Accused.

x--------------------------------------------------------------------------------------x

FORMAL OFFER OF DOCUMENTARY EVIDENCE

P 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

“1” SURVEY PLAN To correlate the testimony in the Judicial Affidavit (Exh. “C” for Plaintiff).

“2” OR To prove that the witness and the Defendants have been paying the real roperty taxes
over Lot.

“3”

Page 146 of 194

4 OR

Sinumpaang-Salaysay PANGHUKOMAN of Ms. Princess C. Atienza

Killing To prove that the witness and the Defendants have been paying the real roperty taxes over Lot

To corroborate the testimony of the first witness;

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.

“4-1” Signature of Ms. Princess C. Atienza To prove that the witness duly executed the affidavit
(Exh. “B”).

“5” Judicial Affidavit of MR. DIONISIO TIRONA To testify as the primary witness for the
Defendants;

Page 147 of 194

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.

“5-1” Signature of Mr. DIONISIO TIRONA To prove that the witness duly executed the affidavit
(Exh. “C”).

“D” Judicial Affidavit of To prove the performance of his duty as First Responder and
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.

“D-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the affidavit
(Exh. “D”).

“E” Letter Endorsement to the Office of the Provincial Prosecutor/Police Report To provide the
court information pertaining to the commission of the crime of murder by the accused.

“E-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the Letter
Endorsement/Police Report (Exh. “E”).

“F” Pinagsamang Sinumpaang-Salaysay of PO2 David P. Nepomuceno and Mr. Jerry Pascua To
correlate the testimony in the Judicial Affidavit of the second witness.

“F-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the
affidavit (Exh. “F”).

“G” Crime scene picture of the body of the victim To provide the court information as to the
physical condition of the victim.

“H”

“F-1” Medical Necropsy and Toxicology To submit to the court information of the cause
of death of the accused

To corroborate the testimony of the first witness;

To correlate the report with the commission of the crime.

“F-2” Picture of dead Maria Labo To support the proof of the death of the
accused.

“G-1” Crime Scene picture of the kitchen 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 the Cauldron To prove the existence of one of 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.

Page 148 of 194

 Aforesaid exhibits are all being offered to prove that the cause of action and claim against the
Heirs of Tirona by Plaintiffs are not true and have no basis in fact and in law.

WHEREFORE, premises considered, it is most respectfully prayed to this Honorable Court that
the foregoing documentary exhibits, along with the testimonies given by the Defendants’ witnesses, BE
ADMITTED for which each and all said exhibits were formally offered and submitted and, ultimately, for
the purpose of disproving the claims of the Plaintiffs and in support of the defenses set forth in the
Defendants’ Answer to the Complaint.

Makati City.

August 11, 2014

BIAG NI LAM-ANG

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.

BIAG NI LAM-ANG

City Assistant Prosecutor

Copy Furnished:

Page 149 of 194

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

Republic of the Philippines

TWELFTH JUDICIAL REGION

REGIONAL TRIAL COURT

Branch 14

Cotabato City

HEIRS OF DATU MAMADRA

MASTURA,

Plaintiffs,

For: MURDER

-versus-

JOEY CRUZ y VALENCIANO,

Accused.

x--------------------------------------------------------------------------------------x

FORMAL OFFER OF DOCUMENTARY EVIDENCE

P by the undersigned counsel and unto this Honorable Court, most respectfully offers the following
documentary and exhibits for the above titled case, to wit:

Page 150 of 194

EXHIBITS DESCRIPTION PURPOSE/S

“1” SURVEY PLAN To correlate the testimony in the Judicial Affidavit (Exh. “C” for Plaintiff).

“2” OR To prove that the witness and the Defendants have been paying the real roperty taxes
over Lot.

“3”

4 OR

Sinumpaang-Salaysay PANGHUKOMAN of Ms. Princess C. Atienza

Killing To prove that the witness and the Defendants have been paying the real roperty taxes over Lot

Page 151 of 194

To corroborate the testimony of the first witness;

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.

“4-1” Signature of Ms. Princess C. Atienza To prove that the witness duly executed the affidavit
(Exh. “B”).

“5” Judicial Affidavit of MR. DIONISIO TIRONA To testify as the primary witness for the
Defendants;

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.

“5-1” Signature of Mr. DIONISIO TIRONA To prove that the witness duly executed the affidavit
(Exh. “C”).

“D” Judicial Affidavit of To prove the performance of his duty as First Responder and
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.

“D-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the affidavit
(Exh. “D”).

“E” Letter Endorsement to the Office of the Provincial Prosecutor/Police Report To provide the
court information pertaining to the commission of the crime of murder by the accused.

“E-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the Letter
Endorsement/Police Report (Exh. “E”).

“F” Pinagsamang Sinumpaang-Salaysay of PO2 David P. Nepomuceno and Mr. Jerry Pascua To
correlate the testimony in the Judicial Affidavit of the second witness.

“F-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the
affidavit (Exh. “F”).

“G” Crime scene picture of the body of the victim To provide the court information as to the
physical condition of the victim.

“H”

“F-1” Medical Necropsy and Toxicology To submit to the court information of the cause
of death of the accused

To corroborate the testimony of the first witness;

Page 152 of 194

To correlate the report with the commission of the crime.

“F-2” Picture of dead Maria Labo To support the proof of the death of the
accused.

“G-1” Crime Scene picture of the kitchen 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 the Cauldron To prove the existence of one of 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 all being offered to prove that the cause of action and claim against the
Heirs of Tirona by Plaintiffs are not true and have no basis in fact and in law.

WHEREFORE, premises considered, it is most respectfully prayed to this Honorable Court that
the foregoing documentary exhibits, along with the testimonies given by the Defendants’ witnesses, BE
ADMITTED for which each and all said exhibits were formally offered and submitted and, ultimately, for
the purpose of disproving the claims of the Plaintiffs and in support of the defenses set forth in the
Defendants’ Answer to the Complaint.

Makati City.

August 11, 2014

BIAG NI LAM-ANG

City Assistant Prosecutor

NOTICE

The Hon. Clerk of Court

Page 153 of 194

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

Republic of the Philippines

TWELFTH JUDICIAL REGION

REGIONAL TRIAL COURT

Branch 14

Cotabato City

HEIRS OF DATU MAMADRA

MASTURA,

Page 154 of 194

 Plaintiffs,

For: MURDER

-versus-

JOEY CRUZ y VALENCIANO,

Accused.

x--------------------------------------------------------------------------------------x

FORMAL OFFER OF DOCUMENTARY EVIDENCE

P 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

“1” SURVEY PLAN To correlate the testimony in the Judicial Affidavit (Exh. “C” for Plaintiff).

“2” OR To prove that the witness and the Defendants have been paying the real roperty taxes
over Lot.

“3”

4 OR

Page 155 of 194

Sinumpaang-Salaysay PANGHUKOMAN of Ms. Princess C. Atienza

Killing To prove that the witness and the Defendants have been paying the real roperty taxes over Lot

To corroborate the testimony of the first witness;

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.

“4-1” Signature of Ms. Princess C. Atienza To prove that the witness duly executed the affidavit
(Exh. “B”).

“5” Judicial Affidavit of MR. DIONISIO TIRONA To testify as the primary witness for the
Defendants;

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.

“5-1” Signature of Mr. DIONISIO TIRONA To prove that the witness duly executed the affidavit
(Exh. “C”).

“D” Judicial Affidavit of To prove the performance of his duty as First Responder and
Investigator within the scope of his duty and regular performance of duty;

Page 156 of 194

To testify to the truth of the affidavit executed;

To identify the victim and the accused.

“D-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the affidavit
(Exh. “D”).

“E” Letter Endorsement to the Office of the Provincial Prosecutor/Police Report To provide the
court information pertaining to the commission of the crime of murder by the accused.

“E-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the Letter
Endorsement/Police Report (Exh. “E”).

“F” Pinagsamang Sinumpaang-Salaysay of PO2 David P. Nepomuceno and Mr. Jerry Pascua To
correlate the testimony in the Judicial Affidavit of the second witness.

“F-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the
affidavit (Exh. “F”).

“G” Crime scene picture of the body of the victim To provide the court information as to the
physical condition of the victim.

“H”

“F-1” Medical Necropsy and Toxicology To submit to the court information of the cause
of death of the accused

To corroborate the testimony of the first witness;

To correlate the report with the commission of the crime.

“F-2” Picture of dead Maria Labo To support the proof of the death of the
accused.

“G-1” Crime Scene picture of the kitchen 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 the Cauldron To prove the existence of one of 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 all being offered to prove that the cause of action and claim against the
Heirs of Tirona by Plaintiffs are not true and have no basis in fact and in law.

WHEREFORE, premises considered, it is most respectfully prayed to this Honorable Court that
the foregoing documentary exhibits, along with the testimonies given by the Defendants’ witnesses, BE
ADMITTED for which each and all said exhibits were formally offered and submitted and, ultimately, for
the purpose of disproving the claims of the Plaintiffs and in support of the defenses set forth in the
Defendants’ Answer to the Complaint.

Page 157 of 194

Makati City.

August 11, 2014

BIAG NI LAM-ANG

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.

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.

Page 158 of 194

 BIAG NI LAM-ANG

City Assistant Prosecutor

Republic of the Philippines

TWELFTH JUDICIAL REGION

REGIONAL TRIAL COURT

Branch 14

Cotabato City

HEIRS OF DATU MAMADRA

MASTURA,

Plaintiffs,

For: MURDER

-versus-

JOEY CRUZ y VALENCIANO,

Accused.

x--------------------------------------------------------------------------------------x

FORMAL OFFER OF DOCUMENTARY EVIDENCE

P 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

“1” SURVEY PLAN To correlate the testimony in the Judicial Affidavit (Exh. “C” for Plaintiff).

“2” OR To prove that the witness and the Defendants have been paying the real roperty taxes
over Lot.

“3”

Page 159 of 194

4 OR

Sinumpaang-Salaysay PANGHUKOMAN of Ms. Princess C. Atienza

Killing To prove that the witness and the Defendants have been paying the real roperty taxes over Lot

Page 160 of 194

To corroborate the testimony of the first witness;

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.

“4-1” Signature of Ms. Princess C. Atienza To prove that the witness duly executed the affidavit
(Exh. “B”).

“5” Judicial Affidavit of MR. DIONISIO TIRONA To testify as the primary witness for the
Defendants;

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.

“5-1” Signature of Mr. DIONISIO TIRONA To prove that the witness duly executed the affidavit
(Exh. “C”).

“D” Judicial Affidavit of To prove the performance of his duty as First Responder and
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.

“D-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the affidavit
(Exh. “D”).

“E” Letter Endorsement to the Office of the Provincial Prosecutor/Police Report To provide the
court information pertaining to the commission of the crime of murder by the accused.

“E-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the Letter
Endorsement/Police Report (Exh. “E”).

“F” Pinagsamang Sinumpaang-Salaysay of PO2 David P. Nepomuceno and Mr. Jerry Pascua To
correlate the testimony in the Judicial Affidavit of the second witness.

“F-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the
affidavit (Exh. “F”).

“G” Crime scene picture of the body of the victim To provide the court information as to the
physical condition of the victim.

“H”

“F-1” Medical Necropsy and Toxicology To submit to the court information of the cause
of death of the accused

To corroborate the testimony of the first witness;

To correlate the report with the commission of the crime.

“F-2” Picture of dead Maria Labo To support the proof of the death of the
accused.

“G-1” Crime Scene picture of the kitchen To provide the court information as to
the place where the crime was committed

To corroborate the testimony of the two witnesses presented.

Page 161 of 194

“G-2” Crime scene picture of the Cauldron To prove the existence of one of 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 all being offered to prove that the cause of action and claim against the
Heirs of Tirona by Plaintiffs are not true and have no basis in fact and in law.

WHEREFORE, premises considered, it is most respectfully prayed to this Honorable Court that
the foregoing documentary exhibits, along with the testimonies given by the Defendants’ witnesses, BE
ADMITTED for which each and all said exhibits were formally offered and submitted and, ultimately, for
the purpose of disproving the claims of the Plaintiffs and in support of the defenses set forth in the
Defendants’ Answer to the Complaint.

Makati City.

August 11, 2014

BIAG NI LAM-ANG

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.

Page 162 of 194

 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

Republic of the Philippines

TWELFTH JUDICIAL REGION

REGIONAL TRIAL COURT

Branch 14

Cotabato City

HEIRS OF DATU MAMADRA

MASTURA,

Plaintiffs,

For: MURDER

-versus-

Page 163 of 194

JOEY CRUZ y VALENCIANO,

Accused.

x--------------------------------------------------------------------------------------x

FORMAL OFFER OF DOCUMENTARY EVIDENCE

P 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

“1” SURVEY PLAN To correlate the testimony in the Judicial Affidavit (Exh. “C” for Plaintiff).

“2” OR To prove that the witness and the Defendants have been paying the real roperty taxes
over Lot.

“3”

4 OR

Page 164 of 194

Sinumpaang-Salaysay PANGHUKOMAN of Ms. Princess C. Atienza

Killing To prove that the witness and the Defendants have been paying the real roperty taxes over Lot

To corroborate the testimony of the first witness;

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.

“4-1” Signature of Ms. Princess C. Atienza To prove that the witness duly executed the affidavit
(Exh. “B”).

“5” Judicial Affidavit of MR. DIONISIO TIRONA To testify as the primary witness for the
Defendants;

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.

“5-1” Signature of Mr. DIONISIO TIRONA To prove that the witness duly executed the affidavit
(Exh. “C”).

“D” Judicial Affidavit of To prove the performance of his duty as First Responder and
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.

“D-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the affidavit
(Exh. “D”).

“E” Letter Endorsement to the Office of the Provincial Prosecutor/Police Report To provide the
court information pertaining to the commission of the crime of murder by the accused.

“E-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the Letter
Endorsement/Police Report (Exh. “E”).

Page 165 of 194

“F” Pinagsamang Sinumpaang-Salaysay of PO2 David P. Nepomuceno and Mr. Jerry Pascua To
correlate the testimony in the Judicial Affidavit of the second witness.

“F-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the
affidavit (Exh. “F”).

“G” Crime scene picture of the body of the victim To provide the court information as to the
physical condition of the victim.

“H”

“F-1” Medical Necropsy and Toxicology To submit to the court information of the cause
of death of the accused

To corroborate the testimony of the first witness;

To correlate the report with the commission of the crime.

“F-2” Picture of dead Maria Labo To support the proof of the death of the
accused.

“G-1” Crime Scene picture of the kitchen 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 the Cauldron To prove the existence of one of 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 all being offered to prove that the cause of action and claim against the
Heirs of Tirona by Plaintiffs are not true and have no basis in fact and in law.

WHEREFORE, premises considered, it is most respectfully prayed to this Honorable Court that
the foregoing documentary exhibits, along with the testimonies given by the Defendants’ witnesses, BE
ADMITTED for which each and all said exhibits were formally offered and submitted and, ultimately, for
the purpose of disproving the claims of the Plaintiffs and in support of the defenses set forth in the
Defendants’ Answer to the Complaint.

Makati City.

August 11, 2014

BIAG NI LAM-ANG

Page 166 of 194

 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.

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

Republic of the Philippines

Page 167 of 194

TWELFTH JUDICIAL REGION

REGIONAL TRIAL COURT

Branch 14

Cotabato City

HEIRS OF DATU MAMADRA

MASTURA,

Plaintiffs,

For: MURDER

-versus-

JOEY CRUZ y VALENCIANO,

Accused.

x--------------------------------------------------------------------------------------x

FORMAL OFFER OF DOCUMENTARY EVIDENCE

P 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

“1” SURVEY PLAN To correlate the testimony in the Judicial Affidavit (Exh. “C” for Plaintiff).

“2” OR To prove that the witness and the Defendants have been paying the real roperty taxes
over Lot.

“3”

Page 168 of 194

4 OR

Sinumpaang-Salaysay PANGHUKOMAN of Ms. Princess C. Atienza

Killing To prove that the witness and the Defendants have been paying the real roperty taxes over Lot

To corroborate the testimony of the first witness;

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.

“4-1” Signature of Ms. Princess C. Atienza To prove that the witness duly executed the affidavit
(Exh. “B”).

Page 169 of 194

“5” Judicial Affidavit of MR. DIONISIO TIRONA To testify as the primary witness for the
Defendants;

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.

“5-1” Signature of Mr. DIONISIO TIRONA To prove that the witness duly executed the affidavit
(Exh. “C”).

“D” Judicial Affidavit of To prove the performance of his duty as First Responder and
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.

“D-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the affidavit
(Exh. “D”).

“E” Letter Endorsement to the Office of the Provincial Prosecutor/Police Report To provide the
court information pertaining to the commission of the crime of murder by the accused.

“E-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the Letter
Endorsement/Police Report (Exh. “E”).

“F” Pinagsamang Sinumpaang-Salaysay of PO2 David P. Nepomuceno and Mr. Jerry Pascua To
correlate the testimony in the Judicial Affidavit of the second witness.

“F-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the
affidavit (Exh. “F”).

“G” Crime scene picture of the body of the victim To provide the court information as to the
physical condition of the victim.

“H”

“F-1” Medical Necropsy and Toxicology To submit to the court information of the cause
of death of the accused

To corroborate the testimony of the first witness;

To correlate the report with the commission of the crime.

“F-2” Picture of dead Maria Labo To support the proof of the death of the
accused.

“G-1” Crime Scene picture of the kitchen 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 the Cauldron To prove the existence of one of 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.

Page 170 of 194

 Aforesaid exhibits are all being offered to prove that the cause of action and claim against the
Heirs of Tirona by Plaintiffs are not true and have no basis in fact and in law.

WHEREFORE, premises considered, it is most respectfully prayed to this Honorable Court that
the foregoing documentary exhibits, along with the testimonies given by the Defendants’ witnesses, BE
ADMITTED for which each and all said exhibits were formally offered and submitted and, ultimately, for
the purpose of disproving the claims of the Plaintiffs and in support of the defenses set forth in the
Defendants’ Answer to the Complaint.

Makati City.

August 11, 2014

BIAG NI LAM-ANG

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.

BIAG NI LAM-ANG

City Assistant Prosecutor

Page 171 of 194

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

Republic of the Philippines

TWELFTH JUDICIAL REGION

REGIONAL TRIAL COURT

Branch 14

Cotabato City

HEIRS OF DATU MAMADRA

MASTURA,

Plaintiffs,

For: MURDER

-versus-

JOEY CRUZ y VALENCIANO,

Accused.

x--------------------------------------------------------------------------------------x

FORMAL OFFER OF DOCUMENTARY EVIDENCE

Page 172 of 194

P 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

“1” SURVEY PLAN To correlate the testimony in the Judicial Affidavit (Exh. “C” for Plaintiff).

“2” OR To prove that the witness and the Defendants have been paying the real roperty taxes
over Lot.

“3”

4 OR

Sinumpaang-Salaysay PANGHUKOMAN of Ms. Princess C. Atienza

Killing To prove that the witness and the Defendants have been paying the real roperty taxes over Lot

Page 173 of 194

To corroborate the testimony of the first witness;

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.

“4-1” Signature of Ms. Princess C. Atienza To prove that the witness duly executed the affidavit
(Exh. “B”).

“5” Judicial Affidavit of MR. DIONISIO TIRONA To testify as the primary witness for the
Defendants;

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.

“5-1” Signature of Mr. DIONISIO TIRONA To prove that the witness duly executed the affidavit
(Exh. “C”).

“D” Judicial Affidavit of To prove the performance of his duty as First Responder and
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.

“D-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the affidavit
(Exh. “D”).

“E” Letter Endorsement to the Office of the Provincial Prosecutor/Police Report To provide the
court information pertaining to the commission of the crime of murder by the accused.

“E-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the Letter
Endorsement/Police Report (Exh. “E”).

“F” Pinagsamang Sinumpaang-Salaysay of PO2 David P. Nepomuceno and Mr. Jerry Pascua To
correlate the testimony in the Judicial Affidavit of the second witness.

“F-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the
affidavit (Exh. “F”).

“G” Crime scene picture of the body of the victim To provide the court information as to the
physical condition of the victim.

“H”

Page 174 of 194

“F-1” Medical Necropsy and Toxicology To submit to the court information of the cause
of death of the accused

To corroborate the testimony of the first witness;

To correlate the report with the commission of the crime.

“F-2” Picture of dead Maria Labo To support the proof of the death of the
accused.

“G-1” Crime Scene picture of the kitchen 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 the Cauldron To prove the existence of one of 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 all being offered to prove that the cause of action and claim against the
Heirs of Tirona by Plaintiffs are not true and have no basis in fact and in law.

WHEREFORE, premises considered, it is most respectfully prayed to this Honorable Court that
the foregoing documentary exhibits, along with the testimonies given by the Defendants’ witnesses, BE
ADMITTED for which each and all said exhibits were formally offered and submitted and, ultimately, for
the purpose of disproving the claims of the Plaintiffs and in support of the defenses set forth in the
Defendants’ Answer to the Complaint.

Makati City.

August 11, 2014

BIAG NI LAM-ANG

City Assistant Prosecutor

NOTICE

Page 175 of 194

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

Republic of the Philippines

TWELFTH JUDICIAL REGION

REGIONAL TRIAL COURT

Branch 14

Cotabato City

Page 176 of 194

HEIRS OF DATU MAMADRA

MASTURA,

Plaintiffs,

For: MURDER

-versus-

JOEY CRUZ y VALENCIANO,

Accused.

x--------------------------------------------------------------------------------------x

FORMAL OFFER OF DOCUMENTARY EVIDENCE

P 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

“1” SURVEY PLAN To correlate the testimony in the Judicial Affidavit (Exh. “C” for Plaintiff).

“2” OR To prove that the witness and the Defendants have been paying the real roperty taxes
over Lot.

“3”

4 OR

Page 177 of 194

Sinumpaang-Salaysay PANGHUKOMAN of Ms. Princess C. Atienza

Killing To prove that the witness and the Defendants have been paying the real roperty taxes over Lot

To corroborate the testimony of the first witness;

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.

“4-1” Signature of Ms. Princess C. Atienza To prove that the witness duly executed the affidavit
(Exh. “B”).

“5” Judicial Affidavit of MR. DIONISIO TIRONA To testify as the primary witness for the
Defendants;

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 178 of 194

“5-1” Signature of Mr. DIONISIO TIRONA To prove that the witness duly executed the affidavit
(Exh. “C”).

“D” Judicial Affidavit of To prove the performance of his duty as First Responder and
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.

“D-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the affidavit
(Exh. “D”).

“E” Letter Endorsement to the Office of the Provincial Prosecutor/Police Report To provide the
court information pertaining to the commission of the crime of murder by the accused.

“E-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the Letter
Endorsement/Police Report (Exh. “E”).

“F” Pinagsamang Sinumpaang-Salaysay of PO2 David P. Nepomuceno and Mr. Jerry Pascua To
correlate the testimony in the Judicial Affidavit of the second witness.

“F-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the
affidavit (Exh. “F”).

“G” Crime scene picture of the body of the victim To provide the court information as to the
physical condition of the victim.

“H”

“F-1” Medical Necropsy and Toxicology To submit to the court information of the cause
of death of the accused

To corroborate the testimony of the first witness;

To correlate the report with the commission of the crime.

“F-2” Picture of dead Maria Labo To support the proof of the death of the
accused.

“G-1” Crime Scene picture of the kitchen 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 the Cauldron To prove the existence of one of 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 all being offered to prove that the cause of action and claim against the
Heirs of Tirona by Plaintiffs are not true and have no basis in fact and in law.

WHEREFORE, premises considered, it is most respectfully prayed to this Honorable Court that
the foregoing documentary exhibits, along with the testimonies given by the Defendants’ witnesses, BE

Page 179 of 194

ADMITTED for which each and all said exhibits were formally offered and submitted and, ultimately, for
the purpose of disproving the claims of the Plaintiffs and in support of the defenses set forth in the
Defendants’ Answer to the Complaint.

Makati City.

August 11, 2014

BIAG NI LAM-ANG

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.

BIAG NI LAM-ANG

City Assistant Prosecutor

Copy Furnished:

Counsel for the Accused

Page 180 of 194

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

Republic of the Philippines

TWELFTH JUDICIAL REGION

REGIONAL TRIAL COURT

Branch 14

Cotabato City

HEIRS OF DATU MAMADRA

MASTURA,

Plaintiffs,

For: MURDER

-versus-

JOEY CRUZ y VALENCIANO,

Accused.

x--------------------------------------------------------------------------------------x

FORMAL OFFER OF DOCUMENTARY EVIDENCE

P 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

“1” SURVEY PLAN To correlate the testimony in the Judicial Affidavit (Exh. “C” for Plaintiff).

Page 181 of 194

“2” OR To prove that the witness and the Defendants have been paying the real roperty taxes
over Lot.

“3”

4 OR

Sinumpaang-Salaysay PANGHUKOMAN of Ms. Princess C. Atienza

Killing To prove that the witness and the Defendants have been paying the real roperty taxes over Lot

Page 182 of 194

To corroborate the testimony of the first witness;

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.

“4-1” Signature of Ms. Princess C. Atienza To prove that the witness duly executed the affidavit
(Exh. “B”).

“5” Judicial Affidavit of MR. DIONISIO TIRONA To testify as the primary witness for the
Defendants;

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.

“5-1” Signature of Mr. DIONISIO TIRONA To prove that the witness duly executed the affidavit
(Exh. “C”).

“D” Judicial Affidavit of To prove the performance of his duty as First Responder and
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.

“D-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the affidavit
(Exh. “D”).

“E” Letter Endorsement to the Office of the Provincial Prosecutor/Police Report To provide the
court information pertaining to the commission of the crime of murder by the accused.

“E-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the Letter
Endorsement/Police Report (Exh. “E”).

“F” Pinagsamang Sinumpaang-Salaysay of PO2 David P. Nepomuceno and Mr. Jerry Pascua To
correlate the testimony in the Judicial Affidavit of the second witness.

“F-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the
affidavit (Exh. “F”).

“G” Crime scene picture of the body of the victim To provide the court information as to the
physical condition of the victim.

“H”

“F-1” Medical Necropsy and Toxicology To submit to the court information of the cause
of death of the accused

To corroborate the testimony of the first witness;

To correlate the report with the commission of the crime.

“F-2” Picture of dead Maria Labo To support the proof of the death of the
accused.

Page 183 of 194

“G-1” Crime Scene picture of the kitchen 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 the Cauldron To prove the existence of one of 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 all being offered to prove that the cause of action and claim against the
Heirs of Tirona by Plaintiffs are not true and have no basis in fact and in law.

WHEREFORE, premises considered, it is most respectfully prayed to this Honorable Court that
the foregoing documentary exhibits, along with the testimonies given by the Defendants’ witnesses, BE
ADMITTED for which each and all said exhibits were formally offered and submitted and, ultimately, for
the purpose of disproving the claims of the Plaintiffs and in support of the defenses set forth in the
Defendants’ Answer to the Complaint.

Makati City.

August 11, 2014

BIAG NI LAM-ANG

City Assistant Prosecutor

NOTICE

The Hon. Clerk of Court

RTC Branch ___ Makati City

Page 184 of 194

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

Republic of the Philippines

TWELFTH JUDICIAL REGION

REGIONAL TRIAL COURT

Branch 14

Cotabato City

HEIRS OF DATU MAMADRA

MASTURA,

Plaintiffs,

Page 185 of 194

 For: MURDER

-versus-

JOEY CRUZ y VALENCIANO,

Accused.

x--------------------------------------------------------------------------------------x

FORMAL OFFER OF DOCUMENTARY EVIDENCE

P 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

“1” SURVEY PLAN To correlate the testimony in the Judicial Affidavit (Exh. “C” for Plaintiff).

“2” OR To prove that the witness and the Defendants have been paying the real roperty taxes
over Lot.

“3”

4 OR

Page 186 of 194

Sinumpaang-Salaysay PANGHUKOMAN of Ms. Princess C. Atienza

Killing To prove that the witness and the Defendants have been paying the real roperty taxes over Lot

To corroborate the testimony of the first witness;

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.

“4-1” Signature of Ms. Princess C. Atienza To prove that the witness duly executed the affidavit
(Exh. “B”).

“5” Judicial Affidavit of MR. DIONISIO TIRONA To testify as the primary witness for the
Defendants;

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.

“5-1” Signature of Mr. DIONISIO TIRONA To prove that the witness duly executed the affidavit
(Exh. “C”).

“D” Judicial Affidavit of To prove the performance of his duty as First Responder and
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.

Page 187 of 194

“D-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the affidavit
(Exh. “D”).

“E” Letter Endorsement to the Office of the Provincial Prosecutor/Police Report To provide the
court information pertaining to the commission of the crime of murder by the accused.

“E-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the Letter
Endorsement/Police Report (Exh. “E”).

“F” Pinagsamang Sinumpaang-Salaysay of PO2 David P. Nepomuceno and Mr. Jerry Pascua To
correlate the testimony in the Judicial Affidavit of the second witness.

“F-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the
affidavit (Exh. “F”).

“G” Crime scene picture of the body of the victim To provide the court information as to the
physical condition of the victim.

“H”

“F-1” Medical Necropsy and Toxicology To submit to the court information of the cause
of death of the accused

To corroborate the testimony of the first witness;

To correlate the report with the commission of the crime.

“F-2” Picture of dead Maria Labo To support the proof of the death of the
accused.

“G-1” Crime Scene picture of the kitchen 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 the Cauldron To prove the existence of one of 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 all being offered to prove that the cause of action and claim against the
Heirs of Tirona by Plaintiffs are not true and have no basis in fact and in law.

WHEREFORE, premises considered, it is most respectfully prayed to this Honorable Court that
the foregoing documentary exhibits, along with the testimonies given by the Defendants’ witnesses, BE
ADMITTED for which each and all said exhibits were formally offered and submitted and, ultimately, for
the purpose of disproving the claims of the Plaintiffs and in support of the defenses set forth in the
Defendants’ Answer to the Complaint.

Makati City.

Page 188 of 194

 August 11, 2014

BIAG NI LAM-ANG

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.

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.

Page 189 of 194

 BIAG NI LAM-ANG

City Assistant Prosecutor

Republic of the Philippines

TWELFTH JUDICIAL REGION

REGIONAL TRIAL COURT

Branch 14

Cotabato City

HEIRS OF DATU MAMADRA

MASTURA,

Plaintiffs,

For: MURDER

-versus-

JOEY CRUZ y VALENCIANO,

Accused.

x--------------------------------------------------------------------------------------x

FORMAL OFFER OF DOCUMENTARY EVIDENCE

P 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

“1” SURVEY PLAN To correlate the testimony in the Judicial Affidavit (Exh. “C” for Plaintiff).

“2” OR To prove that the witness and the Defendants have been paying the real roperty taxes
over Lot.

“3”

Page 190 of 194

4 OR

Sinumpaang-Salaysay PANGHUKOMAN of Ms. Princess C. Atienza

Killing To prove that the witness and the Defendants have been paying the real roperty taxes over Lot

To corroborate the testimony of the first witness;

To testify to the truth of the affidavit executed;

Page 191 of 194

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.

“4-1” Signature of Ms. Princess C. Atienza To prove that the witness duly executed the affidavit
(Exh. “B”).

“5” Judicial Affidavit of MR. DIONISIO TIRONA To testify as the primary witness for the
Defendants;

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.

“5-1” Signature of Mr. DIONISIO TIRONA To prove that the witness duly executed the affidavit
(Exh. “C”).

“D” Judicial Affidavit of To prove the performance of his duty as First Responder and
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.

“D-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the affidavit
(Exh. “D”).

“E” Letter Endorsement to the Office of the Provincial Prosecutor/Police Report To provide the
court information pertaining to the commission of the crime of murder by the accused.

“E-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the Letter
Endorsement/Police Report (Exh. “E”).

“F” Pinagsamang Sinumpaang-Salaysay of PO2 David P. Nepomuceno and Mr. Jerry Pascua To
correlate the testimony in the Judicial Affidavit of the second witness.

“F-1” Signature of PO2 David P. Nepomuceno To prove that the witness duly executed the
affidavit (Exh. “F”).

“G” Crime scene picture of the body of the victim To provide the court information as to the
physical condition of the victim.

“H”

“F-1” Medical Necropsy and Toxicology To submit to the court information of the cause
of death of the accused

To corroborate the testimony of the first witness;

To correlate the report with the commission of the crime.

“F-2” Picture of dead Maria Labo To support the proof of the death of the
accused.

“G-1” Crime Scene picture of the kitchen 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 the Cauldron To prove the existence of one of the
instruments/tools used in killing the victim;

To corroborate the testimony of the two witnesses presented.

Page 192 of 194

“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 all being offered to prove that the cause of action and claim against the
Heirs of Tirona by Plaintiffs are not true and have no basis in fact and in law.

WHEREFORE, premises considered, it is most respectfully prayed to this Honorable Court that
the foregoing documentary exhibits, along with the testimonies given by the Defendants’ witnesses, BE
ADMITTED for which each and all said exhibits were formally offered and submitted and, ultimately, for
the purpose of disproving the claims of the Plaintiffs and in support of the defenses set forth in the
Defendants’ Answer to the Complaint.

Makati City.

August 11, 2014

BIAG NI LAM-ANG

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.

Page 193 of 194

 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

Page 194 of 194