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Republic of the Philippines

REGIONAL TRIAL COURT


FOURTH JUDICIAL REGION
Pasay City
Branch 8

PEOPLE OF THE PHILIPPINES


Criminal Case No: 12-3457-798
- versus - For: MURDER

RHONALD OCAMPO y SARENAS


(St. Francis St., Brgy 176 Maricaban, Pasay City)
Accused.

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

FORMAL OFFER OF EVIDENCE

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

EXHIBITS DESCRIPTION PURPOSE/S


COMPLAINT AFFIDAVIT  This document is
A OF ERYHLL REENA GUIMPATAN being offered to
prove that a case
is filed against the
A-1 PAGE 2 herein accused
 To attest that the
affiant duly caused
SIGNATURE OF THE the preparation of
COMPLAINANT the complaint
A-2 ERYHLL REENA GUIMPATAN affidavit
 This document is
SINUMPAANG SALAYSAY being offered to
B OF ERYHLL REENA GUIMPATAN attest to the
B-1 PAGE 2 incident pertaining
B-2 PAGE 3 to the commission
on the crime of
murder, of his
B3 PAGE 4 husband
 To prove that she
SIGNATURE OF ASSOCIATE had personally
CITY PROSECUTOR examined the
B-4 MA. LUISA SALDO affiant (Exh. “B”)
MARRIAGE CERTIFICATE OF  This document is
ROLLY AND EHRYLL being offered to
C GUIMPATAN prove the
existence of
Marriage between
Rolly and Ehryll
Guimpatan and
the latter being the
proper party to file
a complaint.
 This document is
being offered to
DEATH CERTIFICATE OF ROLLY prove the cause of
D GUIMPATAN death of the victim
AFFIDAVIT OF WITNESS  This document is
E ERYHLL REENA GUIMPATAN being offered to
attest to the
incident pertaining
to the commission
of the crime of
murder of the
accused
 To establish the
circumstances
surrounding the
commission of the
crime including the
identity of the
E-1 2ND PAGE accused.
 To prove that the
witness duly
SIGNATURE OF AFFLIANT executed the
E-2 ERYHLL REENA GUIMPATAN Affidavit (Exh “E”)
AFFIDAVIT OF WITNESS  This document is
GENEVIEVE YBANEZ Y being offered to
F BERNANDEZ testify to the truth
as to the
commission of the
crime of murder
 To corroborate
with the testimony
of the first witness
with regards to the
surrounding
circumstances
during the
commission of the
crime and as to the
identity of the
F-1 PAGE 2 accused
 To prove that the
SIGNATURE OF THE AFFIANT witness duly
F-2 GENEVIEVE YBANEZ executed the
Affidavit (Exh “F”)
AFFIDAVIT OF WITNESS  This document is
DANIEL DOMINIC BATULA Y being offered to
G CATALON prove that he was
G-1 PAGE 2 the one who
responded to the
place of incident,
who has secured
the evidence that
could be found in
the crime scene
and was one of the
persons who
arrested the
G-2 PAGE3 accused.
 To prove that the
SIGNATURE OF AFFIANT witness duly
DANIEL DOMINIC BATULA Y executed the
G-3 CATALON Affidavit (Exh “G”)
AFFIDAVIT OF WITNESS  This document is
P/SUPT JESUS ANGELO GOMEZ being offered to
H Y PARAS prove that he was
H-1 PAGE 2 the one who
conducted autopsy
to the victim
 To attest to the
findings on the
autopsy he
H-2 PAGE 3 conducted.
 To prove that the
SIGNATURE OF AFFIANT he duly executed
P/SUPT JESUS ANGELO GOMEZ the Autopsy Report
H-3 Y PARAS (Exh “H”)
MEDICOLEGAL BY P/SUPT  This document is
I JESUS A GOMEZ Y PARAS being offered to
I-2 ANATOMICAL SKETCH (HEAD) prove that he was
the one who
conducted autopsy
to the victim.
 To attest on the
characteristics of
the injuries
sustained by the
victim
 To prove by
determining the
cause of death of
I-3 ANATOMICALSKETCH (BODY) the victim.
PICTURE OF THE KNIFE WITH  To prove the
J BLACK HANDLE MARKED AS existence of the
“RSO” instruments used
in killing the victim
 To corroborate the
testimony of the
witnesses that
were presented
 To prove the
existence of the
instruments used
in killing the victim
 To corroborate the
testimony of the
ACTUAL KNIFE USED BLACK witnesses that
J-1 HANDLE MARKED AS “RSO” were presented
 To provide the
court information
as to the Physical
Condition of the
PICTURE OF THE VICTIM LYING victim at the time
K ON THE FLOOR of the incident
 To provide the
court information
as to the Physical
Condition of the
PICTURE OF THE FACE VICTIM victim when
WITH THE INJURIES HE brought at the
L SUSTAINED funeral service

 This document is
INVOICE ISSUED BY REST IN being offered to
M PEACE MEMORIAL SERVICES prove that the
victim was given a
funeral service
amounting to
Php 50, 000.
PHP 50, 000 AS AMOUNT
RECEIVED AS PAYMENT FOR
M-1 MEMORIAL SERVICES
 This document is
being offered to
INVOICE ISSUED BY QUASI prove that the
M-2 GENERAL HOSPITAL victim was brought
to the hospital after
the incident and
paid the amount
PHP 50,000 AS AMOUNT worth Php 50, 000
RECEIVED AS PAYMENT FOR as hospital
M-3 HOSPITAL SERVICES expenses
REQUEST FOR AUTOPSY BY  This document is
N ERRHYL GUIMPATAN TO THE being offered to
PNP CRIME LABORATORY prove the cause of
death of the Victim
as well as to
ascertain the
severity of injuries
he sustained.
 To prove the
existence of the
instruments used
in killing the victim
 To corroborate the
testimony of the
ACTUAL KNIFE USED BROWN witnesses that
O HANDLE MARKED AS “RSO1” were presented

 To provide the
court as to the
SHORTS OF THE VICTIM circumstances of
RHONALD OCAMPO MARKED the victim
P AS “RSO2”
 This document is
being offered to
prove the incidents
that happened at
the time they
responded at the
scene
SPOT REPORT ON A STABBING  To corroborate
INCIDENT ISSUED BY PO1 with the testimony
Q DANIEL DOMINIC BATULA of the witnesses
R REQUEST FOR BLOOD EXAM  This document is
SIGNATURE OF P/SUPT DANIEL being offered to
R-1 DOMICI BATULA ascertain whether
S CHEMISTRY REPORT the bloodstains on
the evidence which
were recovered
matches the blood
of the Victim
 To prove that it
was P/Supt Daniel
Batula who
requested for the
Blood Exam of the
Victim.
 To prove that a
forensic chemist
was the one who
examined the
SIGNATURE OF THE FORENSIC specimens and
S-1 CHEMIST had executed the
Chemistry Report
 To provide the
court information at
PICTURE OF THE BLOODY which the body of
PAVEMENT AT THE SCENE OF the victim was
T THE CRIME found
AFFIDAVIT OF WITNESS  This document is
U OF PO1 CLARENCE LASAM being offered to
U-1 PAGE 2 prove that he was
the one of the
police officers who
went to the place
of incident to
respond to a
reported incident
and was one of the
person who
arrested the
accused
 To prove that he
was the one who
secured the
evidence which
includes the taking
the picture of the
U-2 SIGNATURE OF AFFIANT bloody pavement.
 This document is
being offered to
prove that he is an
employee of the
said company
EMPLOYMENT ID OF WITNESS which has provided
MARC GARCIA funeral services to
V the victim
 This document is
being offered to
establish that he
was the one who
took picture of the
lifeless body of the
victim when it was
brought at the
funeraria.
 To prove that he
and was the one
who received the
amount of Php 50,
000 and issued
AFFIDAVIT WITNESSS Invoice #1 as proof
W CASHIER MARC GARCIA of payment for the
victim’s Memorial
Services Bills
 To attest to the
truthfulness of the
affidavit he
SIGNATURE OF AFFIANT executed (Exh
W-1 MARC GARCIA “W”)
CERTIFICATE OF EMPLOYMENT  This document is
OF CASIER WITNESS being offered to
X RYNNAH REYNALDO establish that she
EMPLOYMENT ID OF CASHIER is really an
WITNESS employee of Quasi
X-1 RYNNAH REYNALDO General Hospital
 To prove that he
had received the
payment of Php
50, 000 and was
the one who
issued Invoice
#100 as proof for
AFFIDAVIT OF WITNESS OF the victim’s
CASHIER hospitalization
Y RYNNAH REYNALDO expenses

The 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.

PRAYER

Wherefore the 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.

Other reliefs are likewise prayer for.

11 February 2019, Pasay City

______________________
RYNNAH B. REYNALDO
City Prosecutor
MCLE Compliance No. II-0098795
Dated June 9, 2015
NOTICE

The Honorable Clerk of Court


RTC Branch ______ Pasay City

GREETINGS:

Please submit the foregoing Formal Offer for the consideration and approval
of the Honorable Court immediately upon receipt thereof.

______________________
RYNNAH B. REYNALDO
City Prosecutor

Copy Furnished:

Atty. Maui Polangcos


(Counsel for the Accused)
Group One Defense Attorneys Law Office
2452 Donada St., Brgy 32, Pasay City

EXPLANATION

Copies of the foregoing Formal Offer are served upon counsel of the accused
and filed with the Court by personal service

_____________________
RYNNAH B. REYNALDO
City Prosecutor