REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

12th Judicial Region
Branch 17
Makati, City

THE PEOPLE OF THE PHILIPPINES

Plaintiff,

- versus - Criminal Case No. 8972018

For: Qualified Theft under
Art. 310 of the Revised Penal
Code
JC Reyes
Accused,
X------------------------------------------------------------------------------------------------------X

FORMAL OFFER OF EVIDENCE

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

EXHIBITS DESCRIPTION PURPOSE

“A” Sinumpaang-Salaysay of  To prove the fact of
Marie Santos the crime charge
against the accused;
 To establish the
circumstances
surrounding the
commission of the
crime;

“A-1” Signature of Ms. Marie  To prove that the

Santos. witness duly executed
the affidavit (Exh.
“A”)
“B” Sinumpaang-Salaysay of  To test that accused’s
Ms. Loida Magtalas – HR sudden absence
 Manager. proved her guilt to the
crime of Theft.
 To provide facts on
how it was found out
that a sum of money
was missing from the
petty cash box.
“B-1” Signature of Ms. Loida  To prove that the
Magtalas. witness duly executed
the affidavit (Exh.
“B”)
“C” Sinumpaang Salaysay of  To testify the
Mr. Ford Meneses – IT demeanor of accused
Manager when she left the
office at the time of
the complained
incident.
 To explain the
screencap from the
CCTV footages
showing the unusual
acts accused had been
doing on the day of
the incident.
“C-1” Signature of Mr. Ford  To prove that the
Meneses – IT Manager witness duly executed
the affidavit (Exh.
“C”)
“D” Screeencaps of CCTV  To show that accused
footages was the last employee
who left the office on
the night of the
incident;
 To present images
leading accused to be
the person who
committed the crime
of theft.
“E” Sinumpaang Salaysay of  To provide
 Mr. Alberto Mundo – information based on
Security Guard. his observation of the
accused compared to
her actions when she
left the office
building on the night
of the incident.
“E-1” Signature of Mr. Alberto  To prove that the
Mundo. witness duly executed
the affidavit (Exh.
“E”)
“F” Contract of Employment  To prove existence of
employer-employee
relationship.
“G” Screencaps of text messages  To provide proof that
between Loida Magtalas as the HR Manager,
and Accused. Ms. Magtalas had
been trying to contact
Accused when latter
failed suddenly to
report to work .
“H” November 2018 Monthly  To show that accused
Accounting Report – signed the subject
signed. monthly report which
she alleged to have
refused to be
accountable to based
on her contention that
Marie Santos was
forcing her to do
adjustments against
her will.

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.

January 12. 2019.

MAKATI CITY PROSECUTOR’S OFFICE

Hall of Justice
Makati City

By:

Pros. AJ Barrera
Asst. City Prosecutor
Roll of Attorneys No. 021789
IBP No. 121318 / City of Manila / May 17, 2011
MCLE Exempt
PTR Exempt

NOTICE

The Hon. Clerk of Court

RTC Branch 17 Makati City

GREETINGS:

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

Pros. AJ Barrera
Asst. City Prosecutor

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

Pros. AJ Barrera
Asst. City Prosecutor
 MEMORANDUM

Plaintiff, MARIE SANTOS, through her undersigned counsel, respectfully

submits this Memorandum and state:

STATEMENT OF THE FACTS AND THE CASE

This is a case of violation of Art. 310 of the Revised Penal Code otherwise known
as the crime of Qualified Theft against JC Reyes. The basis for the charge was the
affidavit-complaint executed by Marie Santos as the President of MS Finance, Inc.
where accused was under employ when the offense complained of was committed.
Marie Santos filed the criminal complaint on November 20, 2018 pointing accused as
the person who took 15,000 pesos from the company’s Accounting Department petty
cash box on the evening of October 31, 2018. Plaintiff learned that the