REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

SECOND JUDICIAL REGION
BRANCH 09
Aparri, Cagayan

PEOPLE OF THE PHILIPPINES,

-versus- CRIM. CASE NO. II-14485, 14486,

and 14487 for Qualified Theft

LORETO BUMAGAT, JR.,

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

MOTION TO ADOPT THE MARKING OF EXHIBITS IN THE

PRE-TRIAL ORDER TO THE JUDICIAL AFFIDAVIT OF MR.
RODEL P. CARIAGA AND RICHARD PASCUA

The People, through the undersigned Private Prosecutor under

the direct control and supervision of the Public Prosecutor, unto this
Honorable Court respectfully states:

1. Perusal of the records shows that the markings of exhibits

in the Judicial Affidavits of Mr. Rodel P. Cariaga and Mr. Richard
Pascua are different with the markings contained in the Pre-trial Order
dated 30 January 2018.
2. Thus, for consistency, undersigned counsel now moves to
adopt the markings of documents as reflected in the Pre-trial Order to
the Judicial Affidavit of Mr. Rodel P. Cariaga and Mr. Richard Pascua.

Adopt as Exhibit Marked in Description

Judicial Affidavit
as Exhibit

1
“B” “A” Amended Articles of
Incorporation of Easy Bio
(Attached in Philippines, Inc.
Judicial Affidavit of
Rodel P. Cariaga)
“A” “B” Secretary’s Certificate of
Rodel P. Cariaga dated 25
(Attached in January 2019
Judicial Affidavit of
Rodel P. Cariaga)
“D” “C” Letter Addressed to C.V.
Azarcon Mini Balut dated
(Attached in 13 November 2015
Judicial Affidavit of
Rodel P. Cariaga)
“H” “D” Letter Addressed to
Bienvenido Villaruz dated
(Attached in 31 March 2016
Judicial Affidavit of
Rodel P. Cariaga)
“E” “E” Sales Invoice No. 34293
amounting to P121,800.00
(Attached in
Judicial Affidavit of
Rodel P. Cariaga)
“F” “F” Delivery Receipt No.
010784
(Attached in
Judicial Affidavit of
Rodel P. Cariaga)
“J” “G” BDO Deposit Slips

(Attached in
Judicial Affidavit of
Rodel P. Cariaga)
“L” “H” Demand Letter Addressed
to Mr. Bumagat dated 22
(Attached in June 2016
Judicial Affidavit of
Rodel P. Cariaga)
“M” “I” Demand Letter Addressed
to Mr. Bumagat dated 19
(Attached in February 2018
Judicial Affidavit of
Rodel P. Cariaga)
2
 “K” “A” Written Statement of
Richard Pascua
(Attached in
Judicial Affidavit of
Richard Pascua)

PRAYER
WHEREFORE, it is respectfully prayed for that the marking of
exhibits in the Pre-Trial Order be adopted and such markings be
similarly referred to in the Judicial Affidavit of Mr. Rodel P. Cariaga
and Mr. Richard Pascua.

Respectfully submitted.

Aparri, Cagayan, 28 February 2019

Private Prosecutor

By:

With my conformity:

HON. PUBLIC PROSECUTOR

Copy Furnished:

PUBLIC ATTORNEYS OFFICE

Aparri, Cagayan