REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
MAKATI CITY
Branch 211

PEOPLE OF THE PHILIPPINES,

Plaintiff,
CRIM. CASE NO. 123456
-versus- For: Murder, Art. 248(3), RPC

QUENNIE D.V. WHITE,

Accused.
x-----------------------------------x

FORMAL OFFER OF DOCUMENTARY EVIDENCE

The Office of the City Prosecutor through the undersigned Assistant

City Prosecutor, and unto this Honorable Court, most respectfully offers in
evidence the following exhibits for the above titled case, to wit:

Exhibit Document/Description Purpose/s

A and A-1 Complaint Affidavit of To prove the motive of
Linda Happy; the accused to kill the
victim;
To prove that Snow
White received a
chocolate coated apple
from the accused on
May 26, 2018;
To form part of the
testimony of the
witness;
Signature of Linda Happy To prove the existence
and due execution of
the Complaint Affidavit.
B Medical Abstract issued To prove the existence
by Dr. Babaylan Doc of and due execution of
Far-far Away Hospital the Medical Abstract on
May 26, 2018.
To prove that Snow
White died of poisoning.
To prove that the poison
used to kill Snow White
was organophospate.

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C and C-1 Photograph of a brown To show the receptacle
bottle with yellow containing the poison as
stopper and an ‘X’ discovered by the
Marking; Criminal Investigation
Unit – Women’s and
Actual bottle as Children’s desk during
described its investigation found in
a kitchen bin of the
White residence, which
was presented to the
investigator and
photographed by the
latter;
To corroborate that the
same bottle was seen by
witness Cecil Dopey
used by Quinnie White
in concocting the
poisonous chocolate
mix.
D and D-1 Affidavit of Cecil Dopey; To prove that Quinnie
White was seen
preparing a chocolate
mix with an unusual
ingredient contained in
a brown bottle with a
yellow stopper and an
“X” mark during the
party on May 26, 2018;
To prove that the brown
bottle was the same
bottle found by the
police investigators in
the kitchen bin.
Signature of Cecil Dopey To prove the existence
and due execution of
the affidavit;
To form part of the
testimony of the
witness.
E and E-1 Affidavit of Roberto To prove that Quinnie
Sneezy White went to the
garden shed looking for
something at past
midnight during the

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 party;
Signature of Roberto To attest that a bottle of
Sneezy insecticide was
discovered missing in
the morning of May 26,
2018.
F Police Report dated May To prove its existence
26, 2018 and that standard
operating procedure
was observed in filing
the case;
To prove that upon
conduct of a consented
search in the White
residence, the brown
bottle containing
Baygone was found in
the kitchen bin;
To show the passive
attitude, as noted by the
investigating officers, of
the accused during the
investigation
G Warrant of Arrest To prove the valid and
lawful arrest of the
accused;
H and H-1 PNP Arrest and Booking; To prove that the
Fingerprint Report accused was arrested in
relation to this case;
To prove the regularity
of the accused’s
detention procedure;
To demonstrate the
identity of the
fingerprints taken from
the accused in the
course of recording her
arrest, with that of the
fingerprints found on
the brown bottle
containing the poison
that killed Snow White.
I Forensic Report of To prove that the
Object Evidence accused’s fingerprints
(Fingerprint Analysis were present on the

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 Report MLI No. 0001- bottle containing the
001-2018) poison as can be
compared with the
fingerprints in the Arrest
and Booking Report.
J CCTV Footage at the Your Honor, the
Kitchen of the White prosecution respectfully
Residence manifests that this
evidence was reserved
during the pre-trial, and
the same is being
withdrawn and
dispensed with.
K Medical Records of To prove that Snow
Snow White from Dr. White was afflicted
Pedro Tisan since childhood with
Pseudocholinesterase
Deficiency, a rare
enzyme deficiency,
which rendered her very
vulnerable to
organophosphate
poisoning.
L and L-1 Affidavit of Dr. Babaylan To affirm to the due
Doc execution and contents
of the Medical Abstract
issued from Far-far
Away Medical Center on
May 26, 2018 through
Dr. Babaylan Doc.
Signature of Dr. To prove the due
Babaylan Doc execution of the
affidavit.
M and M-1 Affidavit of PO3 Pare Po To affirm to the due
Signature of PO3 Pare Po execution and contents
of the Police Report
dated May 26, 2018.
N and N-1 Affidavit of Dr. Pedro To prove the due
Tisan; execution and contents
Signature of Dr. Pedro of the medical history of
Tisan Snow White.
To affirm the fact that
Snow White was Dr.
Pedro Tisan’s regular
patient.

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O and O-1 Affidavit of Inspector To affirm that a
Inpesktor Gadget fingerprint analysis was
done on the brown
bottle recovered by the
Crime Investigation Unit
from the kitchen bin of
the White residence.
Signature of Insp. To prove the due
Inspector Gadget execution of the
fingerprint analysis.

All documentary exhibits are likewise offered as part of the

testimonies of the witnesses who testified and /or identified the same.

PRAYER
Wherefore, it is respectfully prayed that the aforementioned exhibits
be admitted for the purposes for which they are being offered.

Makati City
October 31, 2018

OFFICE OF THE CITY PROSECUTOR

MAKATI CITY
th
20 Floor, Hall of Justice
0908 Malugay Street, Makati City

ATTY. JOHN KELLY CAINDAY

Assistant City Prosecutor
Roll of Attorney’s No. 12345
IBP No.: 123456; 01/02/19; Makati City
PTR No.: 1234567; 01/02/2018; Makati City
MCLE Compliance No. V-0012345

COPY FURNISHED:
ATTY. JOHN CRISTIAN CONCEPCION
Public Attorney’s Office
22nd Floor, Hall of Justice
0908 Malugay Street, Makati City

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