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REPUBLIC OF THE PHILIPPINES

OFFICE OF THE CITY PROSECUTOR


Makati City

PEOPLE OF THE PHILIPPINES


plaintiff

versus CRIMINAL CASE. 1001001


FOR: PARRICIDE

TENIENTE GIMO
defendant

XX---------------------------------------------------------XX

FORMAL OFFER OF OBJECT AND 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” Affidavit of Ms. Maria Mae  To testify as the primary witness to the
Killing 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 parricide by the
accused;
 To prove the fact of the crime charge against the
accused;
 To establish the circumstances surrounding the
commission of the crime.

“B” SOCO Report of Bernardo Carpio  To testify to the genuineness and due execution
of the SOCO report;
 To establish the presence of the accused at the
scene of the crime;
 To establish the circumstances surrounding the
commission of the crime;
 To testify and correlate the pieces of evidence
acquired from the scene of the crime with the
commission of said crime;
 To prove performance of his duty as First
Responder and Investigator within the scope of
his authority and regular performance of duty.

“C” Bolo with wooden handle  To prove the existence of one of the
inscribed with “Property of instruments/tools used in immobilizing the
Teniente Gimo” victim;
 To prove the fact that the accused is the owner of
thing used in killing the victim;
 To identify the tool where the fingerprints
belonging to the accused were lifted and

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processed in relation to the Fingerprint Analysis
Report.

“C-1” Blanket marked with “Property of  To corroborate the testimony of the first witness;
Teniente Gimo”  To prove the existence of one of the materials
used in carrying the victim;
 To prove the fact that the accused is the owner of
thing used in killing the victim.

“D” Loomband acquired from the  To corroborate the testimony of the first witness;
victim  To prove the existence of one of the materials
used in identifying the victim or that which
caused the accused to identify the victim.

“E” Fingerprint Analysis Report  To corroborate the testimony of the first witness;
 To submit to the court the outcome of the
fingerprint report as lifted from the following
evidence: Bolo, Glass 1, Glass 2, Tray;
 To identify the persons who had contact with the
evidence under investigation and correlate it with
the commission of the crime.

“E-1” Substance Analysis Report  To corroborate the testimony of the first witness;
 To submit to the court the outcome of the
substance analysis report as acquired from the
following evidence: Glass 1, Glass 2;
 To identify the substance used upon the victim
and correlate it with the commission of the
crime.
 To provide the court information that the liquid
substance (Item #543) was a combination of
water, camellia senensis and the drug Zolpidem
in excessive dose approximately 100mg, while
Item #544 was only a combination water and
camellia senensis (tea).

“F-1” Medical Necropsy and  To submit to the court information of the cause
Toxicology of death of the accused
 To corroborate the testimony of the first witness;
 To correlate the report with the 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  To provide the court information as to the place
kitchen where the crime was committed
 To corroborate the testimony of the two
witnesses presented.

“G-2” Crime scene picture of the  To prove the existence of one of the
Cauldron instruments/tools used in killing the victim;
 To corroborate the testimony of the two
witnesses presented.

“G-3” Crime Scene picture of the body  To provide the court information as to the
on the table, covered with the circumstance of the victim;
Blanket (“C-1”)  To corroborate the testimony of the two
witnesses presented.

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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

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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