Republic of The Philippines

REGIONAL TRIAL COURT IN CITIES

First Judicial Region
Branch 5
Baguio City

PEOPLE OF THE PHILIPPINES,

Plaintiff, CRIM CASE No. 38919-R & 38920-R

For: Violation of R.A. 110175

- versus -

MICHELLE GUIANG and MARY

JANE NACAR,
Accused,
x-----------------------x

OMNIBUS MOTION TO REMARK DOCUMENTARY EVIDENCE

With FORMAL OFFER OF EVIDENCE for the PROSECUTION

With all due respect.

The Prosecution, by the undersigned counsel under the direct control and
supervision of the Public Prosecutor, respectfully state that:

FORMAL OFFER OF EVIDENCE

WITH ALL DUE RESPECT.

COMES NOW the Petitioner by and through the undersigned counsel, unto
this Honorable Court, most respectfully submits the following documentary
evidence for its consideration and admission:

EXHIBIT NATURE OF DOCUMENT:

Exhibit A NOTARIZED PETITION WI AFFIDAVIT & VERIFICATION

PURPOSE: Exhibit A is being offered to prove the existence of the Documents

and to prove that the petitioner have the intention of renewing the franchise
subject of this petition, as well as the existence and due execution of all the
attachments, proving compliance with the procedural and formal requirements
of renewing a franchise with the Honorable LTFRB.

Exhibit “B” Franchise Decision

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 PURPOSE: Exhibit “B” and its components are being offered to prove that the
Franchise sought to be renewed was duly issued in accordance with existing
laws.

Exhibit “C” ORIGINAL RECEIPT

Exhibit "C-1-” CERTIFICATE OF REGISTRATION

PURPOSE: Exhibits “C” and "C-1” are being offered to prove that the Units
subject of the franchise ae authorized to be operated as taxi units showing the
year model of the unit.

Exhibit “D” OPERATOR DATA SHEET

Exhibit “D-1” I.D. PICTURE OF OPERATOR
Exhibit “D-2” COMPLETE DETAILS OF OPERATOR

PURPOSE: Exhibits “D”, “D-1” and “D-2” are being offered to prove the personal
details of the Operator

Exhibit “D-3” VALID DRIVERS LICENSE OF AUTHORIZED DRIVER

PURPOSE: Exhibit “D-3” is being offered to prove that the Authorized Driver is
licensed to drive the subject Unit.

Exhibit “E” CERTIFICATE OF BUSINESS NAME ISSUED BY THE D.T.I

PURPOSE: Exhibit “E” and its components are being offered to prove that the
Petitioner is authorized bylaw to engage in the transportation
business/service.

Exhibit “F” PHILIPPINE PASSPORT

PURPOSE: To prove that petitioner is a Philippine Citizen.

Exhibit “G” INCOME TAX RETURN

PURPOSE: Exhibit “G”, is being offered to prove that Petitioner if financially

capable of conducting transportation service and is paying her income tax.

Exhibit “H” CERTIFICATION FROM THE BARANGAY

Exhibit “I” CERTIFIED TRUE COPY OF TCT_______

PURPOSE: Exhibits “H” and “I” are being offered to prove the existence and
sufficiency of the garage of the taxi unit subject of this petition.

Exhibit “J” PHOTOGRAPH OF UNIT

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 PURPOSE: Exhibit “J”, is being offered to prove the Physical Existence of the
taxi unit.

All Exhibits are being submitted to the Honorable Board.

PRAYER

WHEREFORE, we pray that the above documentary exhibits be all admitted in

evidence for the purpose for which they are offered.

All other relief just and equitable under the premises are likewise prayed for.
Baguio City, Philippines this 15th day of December , 2017.

CHRISTOPHER D. DONAAL
Counsel for Defendants
DONAAL-ARCIAGA and Partners Law Office
Upper Ground Floor, Baden Powell Hotel
26 Gov. Pack Rd., Baguio City
Privilege Tax Receipt No. 3015120; 16 February 2017
IBP Lifetime No. 96875; Mountain Province Chapter
Roll No. 52587; 12 May 2006
MCLE Compliance No. V under process