Republic of the Philippines

REGIONAL TRIAL COURT

National Capital Judicial Region
Branch
Pasay City
PEOPLE OF THE PHILIPPINES,

CRIMINAL CASE NO.

____ and _____

Plaintiff,
-versus-

For: Viol. of Sec. 11 and 12, Art. II

of R.A. No. 9165

ISAIAH GIL MADLAMBAYAN,

Accused.
x-------------------------x
FORMAL OFFER OF EXHIBITS
Prosecution thru the undersigned, to this Honorable Court,
respectfully offers for admission the following exhibits:
EXHIBIT A - Memorandum
Examination dated ___________.

Request

For

Laboratory

EXHIBIT B - Chemistry Report No. _________.

PURPOSES:
To prove their existence, genuineness and due execution;
that the dangerous drugs and paraphernalia seized from the accused,
were submitted to the PNP Crime Laboratory for qualitative and
quantitative examination within 24 hours, and were found positive for
methamphetamine hydrochloride, a dangerous drug; and to prove the
corpus delicti of the crimes charged.
EXHIBIT C - (case number # 1) One heat sealed transparent
plastic sachet marked ___________ with signature, having net weight
of 0.42 gram of methamphetamine hydrochloride (specimen A);
EXHIBIT C-1 - (case number # 1) One heat sealed
transparent plastic sachet marked ___________ with signature,
having net weight of 0.41 gram of methamphetamine hydrochloride
(specimen B);
EXHIBIT C-2 - (case number # 1) One heat sealed
transparent plastic sachet marked ___________ with signature,
having net weight of 3.53 gram of methamphetamine hydrochloride
(specimen C);

EXHIBIT C-3 - (case number # 1) One heat sealed

transparent plastic sachet marked ___________ with signature,
having net weight of 0.36 gram of methamphetamine hydrochloride
(specimen D);
EXHIBIT I - (case number # 2) Five (5) pieces disposable
lighters, collectively marked as ___________ with signature;
EXHIBIT J - (case number # 2) Seventeen (17) pcs. of empty
transparent sachet used for repacking shabu, collectively marked as
______________ with signature.
PURPOSES:
To prove their existence and authenticity; to prove that these
are all the same items recovered from the accused; to prove that
these paraphernalia are used or intended for smoking, consuming or
introducing any dangerous drugs into the body; and to prove the
corpus delicti of the crimes charged.
EXHIBIT K - Cash proceeds worth PhP 22,860.00 in different
denominations composing of 15 pcs. of PhP 1000 paper bill, 2 pcs. of
PhP 500 paper bill, 3 pcs. of PhP 200 paper bill, 53 pcs. of PhP 100
paper bill, 14 pcs. of PhP 50 paper bill and 13 pcs. of PhP 20 paper
bill.
PURPOSES:
To prove their existence and authenticity; to prove that these
are the same peso bills recovered from the accused; and to prove the
corpus delicti of the crimes charged.
EXHIBIT L - Chemistry Report No. _______.
PURPOSES:
To prove its existence, genuineness and due execution; that a
drug test was conducted on the urine sample submitted by accused
and submitted to the PNP Crime Laboratory for examination, and was
found positive for methamphetamine and THC-metabolites, both
dangerous drugs; and to prove the corpus delicti of the crimes
charged.
EXBIHIT M and sub-markings - Receipt/Inventory of Property
Seized.
EXHIBIT N and sub-markings - Certificate of Inventory
PURPOSES:

To prove their existence, genuineness and due execution, and

that an inventory was duly conducted on the dangerous drugs seized
from the accused in compliance with Section 21 of R.A. No. 9165 and
Rule 126 of the Rules of Court.
EXHIBIT O and sub-markings - Six Digital Photographs
PURPOSES:
To prove their existence, genuineness and due execution; that
photographs were taken of the seized dangerous drugs,
paraphernalia and other seized items taken from the possession of
the accused; the photographs were also taken of the signatories to
the Receipt and the Certificate of Inventory, in compliance with
Section 21 of R.A. No. 9165; and to prove the corpus delicti of the
crimes charged.
EXHIBIT P - Certified True Copy of Pasay PNP blotter entry
no. ___, dated _______.
PURPOSES:
To prove its existence, genuineness and due execution; and to
prove the recording of the events that led to the arrest of the accused
for violation of R.A. No. 9165.
EXHIBIT Q - Search Warrant No. ________.
EXHIBIT W - Application for Search Warrant.
EXHIBIT X - Deposition of Witnesses.
EXHIBIT Y - Sketch of the place to be searched.
EXHIBIT BB - Order granting the issuance of search warrant.
PURPOSES:
To prove their existence, genuineness and due execution; to
prove the events that led to the application for, and issuance of,
Search Warrant No. _______; and to prove the corpus delicti of the
crimes charged.
EXHIBIT Z - Memorandum
Examination (on the test buy).

Request

for

Laboratory

EXHIBIT AA - Chemistry Report No. _____ (test buy).

PURPOSES:
To prove their existence and authenticity; to prove that the
specimen recovered from accused in a test buy was submitted to the

PNP Crime Laboratory for qualitative and quantitative examination

within 24 hours, and was found positive for methamphetamine
hydrochloride, a dangerous drug; that these documents were
submitted together with the Application for Search Warrant.
EXHIBIT R - Return of Search Warrant With Prayer to Retain
EXHIBIT S - Order of Judge ________ Allowing Retention
EXHIBIT T - Receipt signed by _________.
PURPOSES:
To prove their existence, genuineness and due execution; that
all the items seized from the accused were promptly delivered to the
Executive Judge; that the dangerous drugs, transparent plastic
sachets with residue containing dangerous drugs, and improvised
glass tooter were retained by ________ for submission to the PNP
Crime Laboratory for qualitative and quantitative examination; and to
prove the corpus delicti of the crime charged.
EXHIBIT U - Receipt issued by ____________ (Clerk of
Court).
PURPOSES:
To prove its existence and authenticity; to prove that _______,
clerk of court, received the specimen and chemistry reports from PCI
Hazel Reyes of the PNP Crime Laboratory.
EXHIBIT V - Joint Affidavit of Arrest
PURPOSES:
To prove its existence, genuineness and due execution; to
prove the events that led to the execution of SW No. _______, and
the arrest of the accused for violation of R.A. No. 9165; and to prove
the corpus delicti of the crimes charged.
With the admission of the foregoing exhibits and its submarkings, together with the testimonies of prosecution witnesses, the
prosecution respectfully rests its case.
WHEREFORE, it is respectfully prayed of this Honorable Court,
that the foregoing exhibits be admitted in evidence for the prosecution
including the testimonies of all prosecution witnesses.
RESPECTFULLY SUBMITTED.
Pasay Ciy, Philippines, __________.

(PROSECUTOR)
Copy Furnished:
(DEFENSE COUNSEL)