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REPUBLIC OF THE PHILIPPINES

MUNICIPAL TRIAL COURT IN CITIES


___________ -o0o-

PEOPLE OF THE PHILIPPINES,


Complainant,

CRIM. CASE NOS. ___________


For: “Qualified Theft”

___________ Accused,
X-----------------X

FORMAL OFFER OF EXHIBITS

COMES NOW, the Private Complainant, by the undersigned


Private Prosecutor and unto this Honorable Court most respectfully
submits the following exhibits by way of formal offer, to wit:

1. Exhibit “A” – Special Power of Attorney notarized on


___________
Exhibit “B” – Secretary Certificate notarized ___________
Purpose: To prove that ___________ is authorized to represent the
METROPOLITAN BANK AND TRUST COMPANY (“Metrobank”) in the
instant case.

2. Exhibit “C” – Transmittal dated ___________


Exhibit “C-1” – Transmittal dated ___________

Purpose: To prove the existence of the transmittals amounting to


TWELVE MILLION FIVE HUNDRED FIFTY FOUR THOUSAND ONE
HUNDRED THIRTY NINE AND 75/100 (P12, 554, 139.75) duly
received by the accused, Mr. Jun Tamba.

3. Exhibit “E” – Case Investigation Report (Audit Report) dated


October 6, 2017 signed by LR Fragante, Head of Internal Audit
Group

Purpose: To prove that Metrobank conducted an internal audit


investigation as a matter of company rules and procedure which
later on relied upon by the subject complaint against the Accused.

4. Exhibit “F” – Letter dated September 20, 2017


Exhibit “F-1” – signature of Ms. Annabel C. So to the said letter
Purpose: To prove that ___________ confessed ___________ (former
Head of the Credit Support Unit of ___________) regarding the taking
of the money.

5. Exhibit “G” – Letter dated ___________


6. Exhibit “G-1” – signature of ___________ to the said letter

Purpose: To prove the admission of the Accused to ___________)


regarding his stolen funds which he used for his personal gain
specifically to pay his personal debts including the credit card bills
of his wife.

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed


that this Honorable Court admit the foregoing exhibits to prove the guilt
of the Accused ___________.

Other reliefs just and equitable under the premise are likewise
prayed for.

Most respectfully submitted.

___________ City, Philippines. July 19, 2019

___________
Private Prosecutor
___________

Under the Control and Supervision of:

__________________________
Public Prosecutor

Copy Furnished:

___________
Counsel for the Accused

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