Republic of the Philippines

MUNICIPAL TRIAL COURT OF ______

Second Judicial Region
PROVINCE OF _______

PEOPLE OF THE PHILIPPINES

Plaintiff, CRIM. CASE NO. 2723 and 2659

-versus- FOR: ATTEMPTED HOMICIDE and

ILLEGAL DISCHRAGE OF
DANELO PAYUMOS, FIREARM
Accused.
x-----------------------------------x

FORMAL OFFER OF DOCUMENTARY EXHIBITS FOR THE

PROSECUTION

Plaintiff, through Private Prosecutor, to the Honorable Court, hereby

formally offers the following documentary exhibits in addition to the testimonial
evidence already adduced in court, thus:

EXHIBIT “A” AFFIDAVIT COMPLAINT

Purpose: It forms part of the direct testimony of the Private Complainant (Joey
S. Perfey), part of the pre-trial and the record of the case. It is offered to prove
that private complainant had instituted the above-cited cases; It is also offered to
prove the fact of the crime against the accused. To established the
circumstances surrounding the commission of the crime.

EXHIBIT “A-1” SIGNATURE OF JOEY S. PERFEY

Purpose: To prove that witness Joey S. Perfey has duly executed his Affidavit
Complaint (Exhibit “A”).

EXHIBIT “B” SWORN STATEMENT EXECUTED BY JOEY PERFEY

Purpose: It forms part of the his direct testimony, part of the pre-trial and
record of the case. It is offered to prove the fact of the crime and to establish the
circumstances surrounding the commission of the crime by the accused.

EXHIBIT “C” AFFIDAVIT OF ALEJANDRO G. SANTIAGO

Purpose: To prove the commission of the crime by the accused against the
person of Joey S. Perfey. It shall corroborate the affidavit complaint and the
Sworn Statement of the private complainant.

EXHIBIT “D” JOINT AFFIDAVIT OF PNP MEMBERS PO3 AARON

TONGOL and SPO1 NESTOR REDITO

Purpose: It forms part of the direct testimony of PO3 Aaron Tongol, part of the
pre-trial and record of the case. It is offered to corroborate the testimony of the
private complainant. To prove that police officers Tongol and Redito conducted
the investigation and arrest of the accused. It is also offered to prove the seizure
of the baseball bat, caliber .45, high cup magazine for caliber .45, 5 live
ammunition from the possession of the accused and 1 empty ammunition.

EXHIBIT “D-1” SIGNATURE OF PO3 AARON TONGOL

EXHIBIT “D-2” SIGNATURE OF NESTOR REDITO

Common Purpose: To prove that PO3 Aaron Tongol and SPO1 Nestor Redito
have duly executed their Joint Affidavit (Exhibit “D”).

EXHIBIT “E” JOINT AFFIDAVIT OF JEFFREY GOROSPE and

FELIX MANOBA

Purpose: It forms part of the direct testimony of Jeffrey Gorospe, part of the
pre-trial and record of the case. It is offered to prove the fact that the crime
charged against the accused is true and actually committed by the accused as
seen by him. It is offered to corroborate the testimony of the witness Joey S.
Erfe.

EXHIBIT “E-1” SIGNATURE OF JEFFREY GOROSPE

EXHIBIT “E-2” SIGNATURE OF FELIX MANOBA

Common Purpose: To prove that Jeffrey Gorospe and Felix Manoba have duly
executed their Joint Affidavit (Exhibit “E”).

EXHIBIT “F” MEDICAL CERTIFICATE ISSUED BY Dr. MOISES LAZARO

Purpose: To prove that Joey S. Perfey, upon examination by the expert

witness was found to have suffered Linear Abrasion back and Linear Abrasion
Buttocks.

EXHIBIT “F-2” SIGNATURE OF DR. MOISES V. LAZARO

Purpose: To prove that Dr. Moises V. Lazaro has duly executed the Medical
Certificate (Exhibit “F”).

EXHIBIT”F-3” Diagnosis: Linear Abrasion Back, Linear Abrasion

Buttocks; Healing period less than 10 days

Purpose: To prove that Joey S. Perfey had suffered Linear Abrasion Back and
Linear Abrasion Buttocks which required a healing period of less than 10 days as
a result of the medical examination conducted by Dr. Moises V. Lazaro.

EXHIBIT “G” SUBJECT FIREARM- CALIBER .45 WITH MARKING DMP-2

Purpose: It is offered as object evidence, to prove that the subject fire arm was
used by the accused in the commission of the crime.

EXHIBIT “I” 1 PIECE MAGAZINE MARKED AS DMP-3

Purpose: It is offered as object evidence.

EXHIBIT “I-1” FIVE (5) LIVE AMMUNITIONS

Purpose: It is offered as object evidence.

EXHIBIT “J” ONE (1) PIECE EMPTY AMMUNITION OF CALIBER .45

Purpose: It is offered as object evidence.

PRAYER

WHEREFORE, it is so respectfully prayed of the Honorable Court to admit

the foregoing documentary exhibits and for the purpose for which they are offered
and to render judgment on the basis thereof.

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

Cabagan, Isabela for ________, ___________, August 02, 2019.

 ATTY. FRANKLIN M. ___________
Private Prosecutor
Roll No. 71940
PTR No. 10793692/ 01- 03-19/Isabela
IBP Receipt No. 081164 / 07-17-2019
MCLE Comp. No. V-0013824 dated 10-01-2018
gm_james0031@yahoo.com / 0905-866-9095
Magiting Bldg., San Marcelino,
Cabagan, Isabela

The Clerk of Court

MTC, _______, ________

Please submit the foregoing Formal Offer of Documentary Exhibits

immediately upon receipt hereof for the favorable consideration of the Honorable
Court. Thank you.

FRANKLIN M. ___________

Copy furnished via registered mail

ATTY. EDWIN O. B________
Counsel for the Accused

EXPLANATION

Copy of the foregoing Formal Offer of Evidence was duly furnished Atty.
Edwin O. B______ in his given address via registered mail pursuant to Section 7
& 11, Rule 13 of the Rules of Court due to distance, time and expense to effect
personal service.

FRANKLIN M. ______________