Republic of the Philippines

REGIONAL TRIAL COURT

FIRST JUDICIAL REGION
Branch 48
Urdaneta City, Pangasinan

PEOPLE OF THE PHILIPPINES,

Plaintiff,
CRIM. CASE NO. U-21997-21999
- versus - For: ILLEGAL SALE OF
DANGEROUS DRUGS, ILLEGAL
POSSESSION OF DANGEROUS
DRUGS AND ILLEGAL POSSESSION
OF DRUG PARAPHERNALIA

JAKE TOMINES y Baroca,

Accused.
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PROSECUTION’S FORMAL OFFER OF EVIDENCE

WITH MOTION FOR REMARKING

THE UNDERSIGNED GOVERNMENT PROSECUTOR, the prosecution respectfully

offers for admission the following exhibits:

Exhibit “A” - Affidavit of Poseur Buyer

“A-1” - Signature of PO2 Apolinario O. Mangsat
Purposes:
1. To prove that a valid buy-bust operation was conducted against the
Accused.
2. As part of the testimony of the poseur buyer PO2 Mangsat.

Exhibit “B” - Affidavit of Arrest

“B-1” - Signature of PO2 Walter D. Siquig
Purposes:
1. To prove the fact of arrest of the accused.
2. As part of the testimony of the arresting officer PO2 Siquig.

Exhibit “C” - Complaint/Assignment Sheet 04-158

Exhibit “D” - Complaint/Assignment Sheet 04-160

Purposes:
1. To prove that the marked money used during the buy-bust operations
was properly documented.
2. To prove that the accused, after arrest, and the items seized from the
accused were properly indorsed to the Urdaneta Police Station for
proper disposition and documentation.
3. As part of the testimonies of PO3 Mangsat, PO2 Siquig, and SPO1
Arnulfo Cayetano, Jr. (SUBJECT OF STIPULATION last August 14, 2017).

Exhibit “E” - One (1) piece PhP500.00 bill marked money marked “AOM”
with Serial Number NM896041.
“E-1” - Markings of PO3 Mangsat “AOM”
Purposes:
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 1. To prove and show that accused actually sold Methamphetamine
Hydrochloride or shabu, a dangerous drug, to poseur buyer PO3
Mangsat.
2. As part of the testimony of PO3 Mangsat and PO2 Siquig.

Exhibit “F” - Coordination Form

Exhibit “G” - Pre-Operation Report
Purposes:
1. To prove that coordination measures were made to PDEA Region 1
Office in La Union before conducting the buy-bust operations.
2. As part of the testimonies of PO3 Mangsat, PO2 Siquig, and SPO1
Marlon S. Ingain.

Exhibit “H” to - Series of computerized pictures depicting the marking and

“H-11” inventory of items seized from accused including the turnover of
the accused to the Urdaneta Police Station.
Purposes:
1. To show and prove that the incident was properly documented.
2. As part of the testimonies of PO3 Mangsat, PO2 Siquig, PB Cheryl Del
Prado, and Ex- Vice Mayor Franco Del Prado.

Exhibit “I” - Confiscation and Inventory Receipt (Drugs)

“I-1” - Signature of PO3 Apolinario O. Mangsat
Exhibit “J” - Confiscation and Inventory Receipt (Non-Drugs)
“J-1” - Signature of PO3 Apolinario O. Mangsat

* Witnesses PB Cheryl Del Prado’s and Ex-Vice Mayor Franco Del Prado’s
testimonies were subject of stipulation last April 24, 2017.
Purposes:
1. To prove that the marking and inventory of the confiscated items
were conducted in the place of seizure.
2. To prove that the marking and inventory of the confiscated items
were conducted in the presence of witnesses required by law.
3. To prove that the incident was properly documented.
4. As part of the testimonies of PO3 Mangsat, PO2 Siquig, PB Cheryl Del
Prado, and Ex- Vice Mayor Franco Del Prado.

Exhibit “K-1” and sub-markings - One (1) heat-sealed transparent plastic sachet
containing white crystalline substance suspected to be shabu
(“hstpscwcs”) with markings “AOM-1 4-10-16 and signature”
“K-1-a” - Markings of PO3 Mangsat on the hstpscwcs

* Witness Forensic Chemist PI Ang’s testimony was subject of stipulation last

August 14, 2017.

Exhibit “K-2” and sub-markings - One (1) heat-sealed transparent plastic sachet
containing white crystalline substance suspected to be shabu
(“hstpscwcs”) with markings “AOM-2 4-10-16 and signature”
“K-2-a” - Markings of PO3 Mangsat on the hstpscwcs

* Witness Forensic Chemist PI Ang’s testimony was subject of stipulation last

August 14, 2017.

Exhibit “K-3” and sub-markings - One (1) heat-sealed transparent plastic sachet
containing white crystalline substance suspected to be shabu
(“hstpscwcs”) with markings “AOM-3 4-10-16 and signature”
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 “K-3-a” - Markings of PO3 Mangsat on the hstpscwcs

* Witness Forensic Chemist PI Ang’s testimony was subject of stipulation last

August 14, 2017.

Exhibit “L-1” and sub-markings - One (1) glas tube tooter with markings
“AOM 4-10-16 and signature”
“L-1-a” - Markings of PO3 Mangsat on the hstpscwcs

* Witness Forensic Chemist PI Ang’s testimony was subject of stipulation last

August 14, 2017.
Purposes:
1. To prove that the specimens submitted for laboratory examination
are the same specimens sold by the Accused to the poseur buyer and
the same specimens examined and brought to court by PI Ang.
2. As part of the testimonies of PI Ang, PO3 Campos and PO2 Siquig.

Exhibit “M” - Request for Laboratory Examination

“M-1” - Stamp of Receipt

* Witness Forensic Chemist PI Ang’s testimony was subject of stipulation last

August 14, 2017.
Purposes:
1. To show and prove that PO3 Mangsat requested for the laboratory
examination of the drug items and the tooter seized from the
Accused.
2. As part of the testimonies of PO3 Mangsat and PI Ang.

Exhibit “N” - Request for Laboratory Examination

Exhibit “O” - Initial laboratory report. (SUBJECT OF STIPULATION last August

14, 2017).
Exhibit “P” - Final laboratory report. (SUBJECT OF STIPULATION last August
14, 2017).
Purposes:
1. To prove that the specimens submitted for laboratory examination
are the same specimens seized from the Accused during the buy-bust
operations.
2. To prove and show that same specimens yielded a positive result to
the test for Methamphetamine Hydrochloride or shabu, a dangerous
drug.
3. As part of the testimonies of PI Ang and PO3 Mangsat.

Exhibit “Q” - Incoming Logbook

Exhibit “Q” - Outgoing Logbook

Exhibit “S” - Chain of Custody Report (SUBJECT OF STIPULATION last August

14, 2017).
Purposes:
1. To show and prove the unbroken chain of custody over the item
subject of this case from the poseur buyer PO3 Mangsat to the
Urdaneta Crime Laboratory Office to Chemist PI Ang to the Evidence
Custodian and back to PI Ang for court presentation.
2. As part of the testimonies of PO3 Mangsat and PI Ang.

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 Exhibit “T” - Bigger plastic pouch where the seized items are placed after
laboratory examination (SUBJECT OF STIPULATION).

Purposes:
1. To show that the seized items were not tampered when it was turned
over to NUP Velasco for safekeeping.
2. To show that the seized items were not tampered when it was
brought to court by PI Ang for court presentation.
3. To show and prove the unbroken chain of custody over the item
subject of this case from the Chemist PI Ang to the evidence
custodian and back to PI Ang for court presentation.
4. As part of the testimony of PI Ang.

Upon admission of the object and documentary evidence, the

prosecution respectfully rests its case.

Respectfully submitted.

Urdaneta City, Pangasinan, October 9, 2017.

FAITH ROSLYNDALE T. CRUZ-TAMBIO

Associate Prosecution Attorney II

The Branch Clerk of Court

RTC, Br. 48
Urdaneta City

Greetings:

Please submit the foregoing Formal Offer of Exhibits for consideration and
resolution of the Honorable Court immediately upon receipt hereof.

FAITH ROSLYNDALE T. CRUZ-TAMBIO

Associate Prosecution Attorney II

Copy furnished:
Atty. Marte Sabelo
Counsel for the Accused
PAO, Urdaneta City

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