Republic of the PhilippinesREGIONAL TRIAL COURT

National Capital Judicial RegionBranch

Pasay City

PEOPLE OF THE PHILIPPINES, CRIMINAL CASE NO. ____ and _____

Plaintiff,

-versus- For: Viol. of Sec. 11 and 12, Art. II of R.A. No. 9165

ISAIAH GIL MADLAMBAYAN,Accused.

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FORMAL OFFER OF EXHIBITS

Prosecution thru the undersigned, to this Honorable Court, respectfully offers for admission the following exhibits:

EXHIBIT “A” - Memorandum Request For Laboratory Examination dated ___________.

EXHIBIT “B” - Chemistry Report No. _________.

PURPOSES:To prove their existence, genuineness and due execution;

that the dangerous drugs and paraphernalia seized from the accused, were submitted to the PNP Crime Laboratory for qualitative and quantitative examination within 24 hours, and were found positive for methamphetamine hydrochloride, a dangerous drug; and to prove the corpus delicti of the crimes charged.

EXHIBIT “C” - (case number # 1) One heat sealed transparent plastic sachet marked ___________ with signature, having net weight of 0.42 gram of methamphetamine hydrochloride (specimen A);

EXHIBIT “C-1” - (case number # 1) One heat sealed transparent plastic sachet marked ___________ with signature, having net weight of 0.41 gram of methamphetamine hydrochloride (specimen B);

EXHIBIT “C-2” - (case number # 1) One heat sealed transparent plastic sachet marked ___________ with signature,

having net weight of 3.53 gram of methamphetamine hydrochloride (specimen C);

EXHIBIT “C-3” - (case number # 1) One heat sealed transparent plastic sachet marked ___________ with signature, having net weight of 0.36 gram of methamphetamine hydrochloride (specimen D);

EXHIBIT “I” - (case number # 2) Five (5) pieces disposable lighters, collectively marked as “___________” with signature;

EXHIBIT “J” - (case number # 2) Seventeen (17) pcs. of empty transparent sachet used for repacking shabu, collectively marked as “______________” with signature.

PURPOSES:To prove their existence and authenticity; to prove that these

are all the same items recovered from the accused; to prove that these paraphernalia are used or intended for smoking, consuming or introducing any dangerous drugs into the body; and to prove the corpus delicti of the crimes charged.

EXHIBIT “K” - Cash proceeds worth PhP 22,860.00 in different denominations composing of 15 pcs. of PhP 1000 paper bill, 2 pcs. of PhP 500 paper bill, 3 pcs. of PhP 200 paper bill, 53 pcs. of PhP 100 paper bill, 14 pcs. of PhP 50 paper bill and 13 pcs. of PhP 20 paper bill.

PURPOSES:To prove their existence and authenticity; to prove that these

are the same peso bills recovered from the accused; and to prove the corpus delicti of the crimes charged.

EXHIBIT “L” - Chemistry Report No. _______.

PURPOSES:To prove its existence, genuineness and due execution; that a

drug test was conducted on the urine sample submitted by accused and submitted to the PNP Crime Laboratory for examination, and was found positive for methamphetamine and THC-metabolites, both dangerous drugs; and to prove the corpus delicti of the crimes charged.

EXBIHIT “M” and sub-markings - Receipt/Inventory of Property Seized.

EXHIBIT “N” and sub-markings - Certificate of Inventory

PURPOSES: To prove their existence, genuineness and due execution, and

that an inventory was duly conducted on the dangerous drugs seized from the accused in compliance with Section 21 of R.A. No. 9165 and Rule 126 of the Rules of Court.

EXHIBIT “O” and sub-markings - Six Digital Photographs

PURPOSES:To prove their existence, genuineness and due execution; that

photographs were taken of the seized dangerous drugs, paraphernalia and other seized items taken from the possession of the accused; the photographs were also taken of the signatories to the Receipt and the Certificate of Inventory, in compliance with Section 21 of R.A. No. 9165; and to prove the corpus delicti of the crimes charged.

EXHIBIT “P” - Certified True Copy of Pasay PNP blotter entry no. ___, dated _______.

PURPOSES:To prove its existence, genuineness and due execution; and to

prove the recording of the events that led to the arrest of the accused for violation of R.A. No. 9165.

EXHIBIT “Q” - Search Warrant No. ________.

EXHIBIT “W” - Application for Search Warrant.

EXHIBIT “X” - Deposition of Witnesses.

EXHIBIT “Y” - Sketch of the place to be searched.

EXHIBIT “BB” - Order granting the issuance of search warrant.

PURPOSES:To prove their existence, genuineness and due execution; to

prove the events that led to the application for, and issuance of, Search Warrant No. _______; and to prove the corpus delicti of the crimes charged.

EXHIBIT “Z” - Memorandum Request for Laboratory Examination (on the test buy).

EXHIBIT “AA” - Chemistry Report No. _____ (test buy).

PURPOSES:To prove their existence and authenticity; to prove that the

specimen recovered from accused in a test buy was submitted to the PNP Crime Laboratory for qualitative and quantitative examination within 24 hours, and was found positive for methamphetamine hydrochloride, a dangerous drug; that these documents were submitted together with the Application for Search Warrant.

EXHIBIT “R” - Return of Search Warrant With Prayer to Retain

EXHIBIT “S” - Order of Judge ________ Allowing Retention

EXHIBIT “T” - Receipt signed by _________.

PURPOSES:To prove their existence, genuineness and due execution; that

all the items seized from the accused were promptly delivered to the Executive Judge; that the dangerous drugs, transparent plastic sachets with residue containing dangerous drugs, and improvised glass tooter were retained by ________ for submission to the PNP Crime Laboratory for qualitative and quantitative examination; and to prove the corpus delicti of the crime charged.

EXHIBIT “U” - Receipt issued by ____________ (Clerk of Court).

PURPOSES:To prove its existence and authenticity; to prove that _______,

clerk of court, received the specimen and chemistry reports from PCI Hazel Reyes of the PNP Crime Laboratory.

EXHIBIT “V” - Joint Affidavit of Arrest

PURPOSES:To prove its existence, genuineness and due execution; to

prove the events that led to the execution of SW No. _______, and the arrest of the accused for violation of R.A. No. 9165; and to prove the corpus delicti of the crimes charged.

With the admission of the foregoing exhibits and its sub-markings, together with the testimonies of prosecution witnesses, the prosecution respectfully rests its case.

WHEREFORE, it is respectfully prayed of this Honorable Court, that the foregoing exhibits be admitted in evidence for the prosecution including the testimonies of all prosecution witnesses.

RESPECTFULLY SUBMITTED.

Pasay Ciy, Philippines, __________.

(PROSECUTOR)

Copy Furnished:(DEFENSE COUNSEL)