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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.
x--------------------------------------------------------------------------------------x

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
of Ms. Dimples F.
Arayata
Killing
To correlate the testimony in the
Judicial Affidavit (Exh. C for
Plaintiff).
A-1 Signature of Ms.
Dimples F. Arayata
To prove that the witness duly
executed the affidavit (Exh. A).
B Sinumpaang-Salaysay
of Ms. Princess C.
Atienza
Killing
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.
B-1 Signature of Ms.
Princess C. Atienza
To prove that the witness duly
executed the affidavit (Exh. B).

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C Judicial Affidavit of
Ms. Dimples F.
Arayata
To testify as the primary witness to
the commission of the crime;
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.
Dimples F. Arayata
To prove that the witness duly
executed the affidavit (Exh. C).
D Judicial Affidavit of
PO2 David P.
Nepomuceno
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

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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 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