Republic of the Philippines

Fourth Judicial Region

Province of Oriental Mindoro
MUNICIPAL TRIAL CIRCUIT COURT IN CITIES
Calapan City

PEOPLE OF THE PHILIPPINES, CRIM CASES NOS. 15214 / 15215

Plaintiff

Versus for

MARICHU P.HUERTO, ESTAFA

Accused.

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JOINT FORMAL OFFER OF DOCUMENTARY EXHIBITS

TO THE HONORABLE COURT comes the undersigned counsel for the accused and most
respectfully offers for admission the following documentary exhibits, namely:

EXH “1” - Sworn Statement of the Accused consisting of 5 pages

“1-A” - 2nd Page
“1-B” - 3rd Page
“1-C” - 4th Page
“1-D” - 5th Page
Purpose: As part of the testimony of the accused; To prove that the checks subject of the
case were not intended for the accused and were issued as guaranty checks only; To further
prove the history of the transaction between the parties;

EXH “2” - Complaint Affidavit of private complainant (common exhibit);

Purpose: To show complainant’s admission on the mode of payment and the details of the
transaction;

EXH “3” - Letter-Reply to complainant’s demand letter;

“3-A” - Signature of Atty. Masangkay

Purpose: - To prove that accused was asking for computation of her payments to the
accused;

EXH “4” - Chinabank Check No. 0072195

“4-A” - Date: November 21, 2011
“4-B” - Amount: P 350,000.00
“4-C” - Signature of Issuer: Liza Lorena Ahorro
Purpose: To prove that the complainant prematurely deposited the guarantee checks subject
of the case on 22 October 2011, when in fact the principal creditor deposited complainant’s
check a month after, or on 21 November 2011.

With the foregoing offer of documentary exhibits and the anticipated admission of the same by
the Honorable Court, the DEFENSE respecttfully rests its case.

After the HonorableCourt shall have ruled on the offer, it is further prayed that the Defense be
given a period of thirty (30) days within which to submit Position Paper/Memorandum of
Arguments.

RESPECTFULLY SUBMITTED. Calapan City, Oriental Mindoro, 26 June 2013.

ATTY. GILBERTO U.REPIZO

Counsel for the Accused
PTR No. 4357912 /1-02-13
IBP No. 921907 / 1-07-13

Copy Furnished:

Atty. Marlon Masangkay

Private Prosecutor

Hon. Dorina H. Joya

City Prosecutor