Republic of the Philippines

National Capital Judicial Region

REGIONAL TRIAL COURT
Branch 118, Pasay City

PEOPLE OF THE PHILIPPINES,

Crim. Case No. R-PSY-19-
01068-CR
- versus - For: Violation of Sec. 11, R.A.
9165

AYMARD CUNETA y FERMIN,

Accused.
x - - - - - - - - - - - - x

FORMAL OFFER OF EXHIBITS

The Prosecution, through the undersigned Public Prosecutor, and

unto this Honorable Court, offers in evidence the testimonies of all the
prosecution witnesses who testified in this case and the following
documentary exhibits for purposes stated hereunder:

EXHIBIT NATURE PURPOSE

“A” and sub- Joint Affidavit of Arrest 1. To prove the material

markings dated 22 February allegation in the information;
2019
2. To prove that accused Cuneta
was validly arrested and
detained;

3. And, as part of the testimony

of witnesses.

“B” and sub- Request for Laboratory 1.To prove that the corpus delicti
 markings Examination dated 22 was endorsed for laboratory
February 2019 examination;

2. To prove the fact of delivery

by P01 Rad Dranto and fact of
receipt by P01 Batusbatusan of
SPD Crime Laboratory;

3. To prove the fact of turn-over

by P01 Batusbatusan and fact of
receipt by PCI Sahagun.

Page two -
Formal Offer of Exhibits
Criminal Case No PSY-19-01068-CR

“C” and sub- Chemistry Report No. To prove that the specimen
markings D-235-19S recovered from accused Cuneta
possession were tested and
found positive for the presence
of Methamphetamine
hydrochloride, a dangerous
drug.

“D” and sub- Request for Drug Test To prove that a request has
markings dated 22 February been made for the drug test of
2019 accused on February 22, 2019.

“E” and sub- Turn-over of Arrested To prove that the arrested

markings Person/s and accused and the object
Confiscated/Seized evidence were turned over to
Evidence the Investigator-on-case SP01
Jay Martinez
 “F” and sub- Chain of Custody 1. To prove that accused Cuneta
markings as well as the object evidence
recovered from him were duly
transferred/turned over to the
persons named in the
document;

2] To prove that the integrity of

object evidence was not
compromised in the process;

3. To prove the fact of delivery

by P01 Rad Dranto of the
specimen to SPD Crime Lab
and the fact of receipt by P01
Batusbatusan; and

4. To prove the fact of turn-over

of the specimen by P01
Batustatusan and fact of receipt
by PCI Sahagun.

Page three -
Formal Offer of Exhibits
Criminal Case No PSY-19-01068-CR

“G” and sub- Receipt/Inventory of 1. To prove that an inventory of

markings Property Seized the confiscated items was
conducted and was duly
witnessed by Brgy. Officials,
representative from the media,
accused and arresting officers;
and
 2. To prove the existence of the
object evidence and its
markings.

“H” and sub- Photographs taken 1. To prove that an inventory of

markings during the conduct of the confiscated items was
physical inventory of conducted at the place where
seized items from accused Cuneta was arrested;
accused Cuneta
2. To prove that the physical
inventory of the seized items
was duly witnessed by
Barangay Officials, a
representative from the media,
the accused and arresting
officers.

“I” and sub- Two [2] heat-sealed The corpus delicti, to establish
markings transparent plastic that indeed dangerous drugs
sachets containing: were recovered from the
1. 0.98 gram possession of accused Cuneta.
marked as SDET-
1 and
2. 0.07 gram
marked as SDET-
2

With the submission and admission of the foregoing testimonial,

documentary [all original attached hereto to form an integral part of the
records of the instant case] and object evidence, the prosecution formally
rests its case.

The prosecution prays for other relief, just and equitable under the
premises.
Page four -
Formal Offer of Exhibits
Criminal Case No PSY-19-01068-CR

20 September 2019, Pasay City, Metro Manila, Philippines.

DOLORES P. RILLERA
Senior Deputy City Prosecutor
MCLE Compliance No. V1-0005714/1-09-18
Roll of Attorneys No. 43173
IBP Lifetime Member No. 07612

Atty. Bernalyn A. Perez

Branch Clerk of Court
RTC Branch 118, Pasay City

Greetings:

Please submit the foregoing Formal Offer of Exhibits for the kind
appreciation of this Honorable Court immediately upon receipt hereof.

DOLORES P. RILLERA
Senior Deputy City Prosecutor
Copy furnished:
Atty. Julie Karen U. Paganaje
Counsel for all the accused
Public Attorney’s Office
Rm. 401, Hall of Justice Bldg.
F. B. Harrison, Pasay City