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Republic of the Philippines

REGIONAL TRIAL COURT


National Capital Judicial Region
Branch 214
Mandaluyong City

PEOPLE OF THE PHILIPPINES,


Plaintiff,

-versus- Criminal Case No. MC08-12065


For: Murder
BENJAMIN CENTENO
EDGAR CAYANAN and
ARMANDO DEHINO,
Accused,

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PROSECUTION’S FORMAL OFFER EVIDENCE

Comes now the undersigned Assistant City Prosecutor and unto this
Honorable Court most respectfully submits this Formal Offer of Evidence for
the government, to wit:

Exhibits Description Purpose

To prove their existence and due execution;

To prove that the affiant swore to the veracity


and truthfulness of his allegations in the
Sworn Statement
aforementioned Sworn Statements;
dated October 29,
“A”
2008 of Manuel Luis
To prove the material allegations of the
Sazon y Balagtas
information;

To prove that the accused committed the


crime charged.
Sworn Statement
dated October 31,
“B” Same purpose as Exhibit “A”
2008 of Manuel Luis
Sazon y Balagtas

Sworn Statement
dated November 12,
“C” Same purpose as Exhibit “A”
2008 of Manuel Luis
Sazon y Balagtas

Sworn Statement
dated November 22,
“D” Same purpose as Exhibit “A”
2008 of Manuel Luis
Sazon y Balagtas

To prove its due execution and existence;

Spot Report dated To prove that the standard operating


“E”
October 8, 2008 procedure was followed with respect to the
crime committed which is the subject matter
of this case.
To prove that a Spot Report was duly signed
Name and Signature by the On-case Investigator Erickson T. Buted
“E-1” of PO3 Erickson T. and SPO4 Jaime G. Masilang Chief of the
Buted Criminal Investigation Unit of Mandaluyong
Police Station

Name and Signature


“E-2” of SPO4 Jaime G. Same purpose as Exhibit “E-1”
Masilang

To prove that the victim Ofelia Salamat left a


Certificate of Live
minor son upon her demise;
“H” Birth of Ian Jasper
Salamat
To prove the issue of Damages.

To prove the fact of death of victim Ofelia


Salamat;
Death Certificate of
“J” Ofelia Salamat To prove the cause of her death;

To prove the corpus delicti of the crime


committed by the accused.
“J-1” Dorsal Portion Same purpose as Exhibit “J”

To prove that the accused Benjamin Centeno


y Cortez was inside the Metrobank, Libertad
Branch prior or the commission of the crime
charged;

To prove the cause of the modus operandi of


“K” Picture of Benjamin the accused in their intended commission of
Centeno y Cortez the crime of Robbery;

To prove the accused was in the vicinity of the


crime scene at the of its commission;

To prove that the accused committed the


crime charged.

To prove the fact of investigation conducted


by the police officer assigned to the case;
Trajectory Exam
“L” Letter requested dated
To prove that the standard operating
October 28, 2008
procedure was followed in the investigation of
murder cases.

Signature of P03
“L-1” Same purpose as Exhibit “L”
Erickson Buted
Signature of SPO2
“L-2” Same purpose as Exhibit “L”
Pablo Roxas

Notation below
(Signature of SOCO
“L-3” Same purpose as Exhibit “L”
personnel)

RESPECTFULLY SUBMITTED.

PRAYER

WHEREFORE, it is most respectfully prayed unto this Honorable Court


that the above-mentioned pieces of evidence be ADMITTED for the purpose for
which they have been offiered.

Other just and equitable reliefs under the premises are likewise prayed
for.

September 12, 2018, City of Mandaluyong.

Office of the City Prosecutor


Halls of Justice, Maysilo Circle,
Mandaluyong City

RECHELLE REGONDOLA
ND
2 Assistant City Prosecutor

The Clerk of Court


RTC Branch 214
Mandaluyong City

GREETINGS:

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

RECHELLE REGONDOLA
2ND Assistant City Prosecutor

Copy furnished:

ATTY. JERIK B. SOLAS


SOLAS LAW OFFICE
Unit 2502, España Tower, Sampaloc, Manila
Counsel for the Accused Benjamin Centeno, Edgar Cayanan and Armando
Dehino

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