Republic of the Philippines

Fourth Judicial Region

REGIONAL TRIAL COURT
Branch ___
Imus, Cavite

PEOPLE OF THE PHILIPPINES,

Plaintiff,

Criminal Case No. 14-124

For: MURDER
-versus-

JOEY CRUZ y VALENCIANO,

Accused.
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FORMAL OFFER OF DOCUMENTARY EVIDENCE

PLAINTIFF 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

“A” Sinumpaang-Salaysay  To correlate the testimony in the

of Ms. Dimples F. Judicial Affidavit (Exh. “C” for
Arayata Plaintiff).
Killing

“A-1” Signature of Ms.  To prove that the witness duly

Dimples F. Arayata executed the affidavit (Exh. “A”).
“B” Sinumpaang-Salaysay  To corroborate the testimony of the
of Ms. Princess C. first witness;
Atienza  To testify to the truth of the
Killing 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.
“B-1” Signature of Ms.  To prove that the witness duly
Princess C. Atienza executed the affidavit (Exh. “B”).

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“C” Judicial Affidavit of  To testify as the primary witness to
Ms. Dimples F. the commission of the crime;
Arayata  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.
“C-1” Signature of Ms.  To prove that the witness duly
Dimples F. Arayata executed the affidavit (Exh. “C”).
“D” Judicial Affidavit of  To prove the performance of his
PO2 David P. duty as First Responder and
Nepomuceno 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  To prove that the witness duly
David P. Nepomuceno executed the affidavit (Exh. “D”).
“E” Letter Endorsement  To provide the court information
to the Office of the pertaining to the commission of
Provincial the crime of murder by the
Prosecutor/Police accused.
Report
“E-1” Signature of PO2  To prove that the witness duly
David P. Nepomuceno executed the Letter
Endorsement/Police Report (Exh.
“E”).
“F” Pinagsamang  To correlate the testimony in the
Sinumpaang-Salaysay Judicial Affidavit of the second
of PO2 David P. witness.
Nepomuceno and Mr.
Jerry Pascua
“F-1” Signature of PO2  To prove that the witness duly
David P. Nepomuceno executed the affidavit (Exh. “F”).
“G” Crime scene picture of  To provide the court information
the body of the victim as to the physical condition of the
victim.
“H” 

“F-1” Medical Necropsy and  To submit to the court information

Toxicology of the cause of death of the accused
 To corroborate the testimony of
the first witness;
 To correlate the report with the

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 commission of the crime.

“F-2” Picture of dead Maria  To support the proof of the death

Labo of the accused.
“G-1” Crime Scene picture  To provide the court information
of the kitchen as to the place where the crime was
committed
 To corroborate the testimony of
the two witnesses presented.

“G-2” Crime scene picture of  To prove the existence of one of

the Cauldron the instruments/tools used in
killing the victim;
 To corroborate the testimony of
the two witnesses presented.

“G-3” Crime Scene picture  To provide the court information

of the body on the as to the circumstance of the
table, covered with victim;
the Blanket (“C-1”)  To corroborate the testimony of
the two witnesses presented.

Aforesaid exhibits are being offered to prove that the crime and
accusation against the accused was true and committed at the address
indicated in the Complaint.

WHEREFORE, premises considered, it is most respectfully prayed to

this Honorable Court that the foregoing object and documentary exhibits be
admitted for which each and all said exhibits were offered in proving the
claims of the complainant/s and with the formal submission of the
aforesaid coupled with the testimonies of the witness who testified thereon.

Makati City.
August 11, 2014

BIAG NI LAM-ANG
City Assistant
Prosecutor

NOTICE

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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

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