OFFER OF TESTIMONY

The testimony of the accused is being offered to prove the genuineness of the police
investigation report prepared by his department; to testify to the veracity of its due
execution; to identify and verify all documents where his signatures are affixed; and to prove
all other related matters, facts and circumstances relevant and material to this case.

1. Q: Please state your name and other personal circumstances.

A: I am RICARDO A. DALISAY, of legal age, Filipino, single and a resident of
Barangay Mankilam, Tagum City, Philippines.

2. Q: What is your occupation?

A: I am the police inspector of the Tagum City Police Office.

3. Q: As a police inspector, what does you work entail?

A: I conduct police investigations and oversee other investigations
conducted by my department.

4. Q: Do you remember having conducted an investigation involving an

accident that happened last December 16, 2017 along the PNP Barracks,
National Highway, Tagum City?
A: Yes, Atty.

5. Q: I have here a document entitled, (police report) Investigation report re:

the death of Ryan Santos due to a traffic accident. Please state the relation of
said document to the investigation you mentioned earlier.
A: That is the same document that my team and I made regarding the said
traffic accident.

6. Q: The last page of this document bears the name, Ricardo A. Dalisay and
above it is a signature, whose signature is this?
A: It is my signature.

Marking: It is respectfully prayed to the Honorable Court that this document

entitled Traffic Investigation Report be marked as Exhibit “___” and the signature
contained therein be marked as Exhibit “___”.

7. Q: Based on your investigation, what were your findings, if any?

A: That it was accused, Reyes, who was behind the wheel when the incident
happened and that there is evidence that it was done voluntarily and
intentionally.
 8. Q: How can you say that the incident was done voluntarily and
intentionally?
A: Based on our investigation, we found out that there were no skid marks
or tire marks in the scene of the incident that should indicate that the driver lost
control of his vehicle. Other than Mr. Reyes' lone testimony, there were no evidence to
prove that he tried to stop his vehicle or that he even tried to swerve the other way to
avoid hitting the couple, Mr. and Mrs. Santos. Instead, we found out that when the
vehicle made a turn in the shoulder of the highway, it did not slacken its speed but
went even faster.

9. Q: How were you able to come up with said finding?

A: Following the standard procedure, we obtained the accounts from the
eyewitnesses and those who initially responded to the accident; as well
as the police report made by one SP02 Adam Sotto.

10. Q: Other than the accounts of those who first responded, what were the
other indications that lead you to conclude that it was Mr. Reyes' car which hit
the couple , if any?
A: We found that there was a slight dent on the front right side of Mr. Reyes’
car where Mr. Santos was hit.

11. Q: What other information did your investigation reveal, if any?

A: We also obtained a statement from Mr. Reyes admitting that it was him
who was driving the car but that the incident happened because he was
having a heart attack at that time.

12. Q: Other than Mr. Reyes’ statement, was he able to show you any other proof
of his heart attack, if any?
A: No. But he did mention that he was not feeling well on the day of the
incident.

13. Q: Other than the fact that it was Mr. Reyes who drove the car when the
incident happened, were you able to find out other circumstances relevant to
this case, if any?
A: Yes, Atty. We found out that Mr. Reyes and Mr. Santos had a prior
altercation.

14. Q: How were you able to discover said altercation?

A: We discovered it through the statement made by Mrs. Santos; and the fact
that her husband filed a police blotter against Mr. Reyes for threats to his
life made during a homeowner's association meeting.
 15. Q: Other than the statement made by Mrs. Santos and the police blotter,
were you able to obtain other proof of said altercation, if any?
A: Yes, Atty. We interviewed other officers of the said association
particularly, the President and Secretary of the Carmina Homeowner's
Association who were present when it happened. They affirmed the
altercation that happened.

16. Q: Were you able to discover the cause of said altercation?

A: Yes, Atty.

17. Q: What was the cause of the said altercation?

A: Mr. Reyes was allegedly humiliated by the implications made by Mr.
Santos of the unexplained shortage of Php 1,500,000.00 in the Homeowner’s
Association Fund especially that it led to his dismissal as the treasurer of the
association.

18. Q: How were you able to discover said cause?

A: We obtained it through the statement made by Mrs. Santos and the other
officers of the homeowner's association who were present when the altercation
happened.

19. Q: Other than their statements, were you able to find any proof of the cause
of the altercation between the victim and the accused, if any?
A: Yes, Atty. We were able to obtain a copy of the audit report which
reflected the deficiency of Mr. Reyes. The said audit report was shown to the
accused and the other officers of the homeowner's association at the time of
said altercation.

20. Q: Mr. Dalisay, based on the findings you made during the investigation you
and your team conducted, what are your conclusions, if any?
A: That it is clear that Mr Reyes is responsible for the incident that
happened on the morning of December 16, 2017 along the PNP Barracks
here in Tagum City and that it was done voluntarily and intentionally.

21. Q: What is your recommendation as stated in your report, if any?

A: It is recommended that a complaint for Murder be filed against Mr. Allan
P. Reyes.

22. Q: Why do you recommend for the filing of Murder?

A: It is because our investigation reveals that the case was attended by the
qualifying aggravating circumstances of treachery and evident premeditation.

23. Q: How is the circumstance of treachery present in the case?

 A: Treachery is present because of the manner by which Reyes executed the
crime, that by using his vehicle and driving it from the victims' backs, assured him that they
would have no way of escaping and also ensured his safety from any retaliation or defense from
them.

24. Q: How about the circumstance of evident premeditation, how is it present

in the case?
A: Evident premeditation is also present because Reyes, being their
longtime neighbor, had knowledge of the routine jog of the spouses. He knew that they
were going to be jogging there at that time. So, he was able to accordingly and
deliberately plan the execution and commission of the crime.

25. Q: Do you have more to say and add?

A: No more, Atty.