REPUBLIC OF THE PHILIPPINES

THIRD JUDICIAL REGION

REGIONAL TRIAL COURT OF MALOLOS
CITY OF MALOLOS, BULACAN
Branch 21

PEOPLE OF THE PHILIPPINES

Complainant,

Criminal Case No. 32194

– versus – For: Violation of Par. 2
Article 266-A of the RPC
(Rape through Sexual Assault)

ARMANDO ESTEVEZ,
ALEJANDRO ALDAMA,
LOUIE MONTEMAYOR,
ELIZABETH ZARAGOSA,
Accused.
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JUDICIAL AFFIDAVIT
(By Way of Direct Examination)

Expert Witness, Forensic Chemical Officer REDJINA DE

LEON-REYES, of legal age, married, Filipino, and with office address
at Camp Alejo S. Santos, City of Malolos, Bulacan, having been duly
sworn to in accordance with law through the supervision of PUBLIC
PROSECUTOR FRANCISCO JEREMIAH SANTOS GONZALES
with office address at the Office of the Provincial Prosecutor of Bulacan,
Capitol Compound, Brgy. Guinhawa, City of Malolos, Bulacan,
conducted at the given address of the public prosecutor, hereby answers
all the questions asked of him with full consciousness under the pain of
criminal liability for false testimony or perjury:

The testimony of this witness is being offered as testimony of an

expert witness to prove that the following:

1. To prove that the witness is an expert in Forensic and DNA

Analysis and Tests;

2. To prove that the expert witness conducted her Forensic and

DNA Tests in accordance to the 2011 Revised Criminal
Investigation Manual, in effect, maintaining the evidentiary
value and preservation of the chain of custody from the time
her office received the samples until release of crime
laboratory results;

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 3. To prove that the blood sample taken not only from the tip
of the subject bottle but also from the bed sheet and bed
cover are blood of the Private Complainant;

4. To prove that the subject one (1) bottle of San Miguel Beer
(San Mig Light) found by the police investigator is the same
hard object inserted into the vagina of the Private
Complainant while sleeping;

5. To prove that the fingerprints found on the tip and lower part
of the bottle are conclusively matched with the Accused
Armando Estevez and Elizabeth Zaragosa;

6. To identify and authenticate documents material to this

instant case;

7. Such other relevant and material allegations to the Petition;

DIRECT EXAMINATION

1. Q: Please state your personal circumstances.

A: REDJINA DE LEON-REYES, of legal age,

married, Filipino, and with office address at Camp
Alejo S. Santos, City of Malolos, Bulacan. I am
currently the Forensic Chemical Officer/DNA
Analysis Officer at Regional Crime Laboratory Office
3 at the said address.

2. Q: Kindly state your educational background leading

to your profession as of this date.

A: I obtained a Bachelor of Science in Biology

Degree from the University of the Philippines Baguio
in the year of 1995. Thereafter, I went to medical
school in the Pamantasan ng Lungsod ng Maynila,
graduated in 2000 and passed the Medical Board
Examinations in 2001. I further continued my studies
and obtained a Master’s Degree in Criminal Justice
with Specialization in Forensic Medicine from the
University of the Cordilleras in 2004.

3. Q: I have here a document, purporting to be a

notarized Curriculum Vitae of one Redjina De Leon-
Reyes, I am now showing to you this document, can
you please identify it?
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 A: This is my curriculum vitae.

Prosec. Gonzales: Your Honor, may I manifest that this Curriculum

Vitae of the witness, as was just identified by her, was already marked
during the Pre-Trial Conference as our Exhibit “__”.

4. Q: and your Curriculum Vitae has attachments,

purporting to be Diplomas from different universities
and other credential, I am now showing you these
documents, can you please identify it?

A: This one diploma is from the University of the

Philippines where I obtained my degree in Biology;
this one is from the Pamantasan ng Lungsod ng
Maynila where I obtained my medicine; this one is
my PRC License Card issued by the Professional
Regulation Commission; and this one is my diploma
where I obtained my Master’s Degree in Forensic
Medicine in University of the Cordilleras;

Prosec. Gonzales: Your Honor, may I manifest that these Diplomas and
one PRC License No. 123456, as were just identified by the witness,
were already marked during the Pre-Trial Conference as our Exhibits
“__”, “__”, “__”, and “__”, respectively.

5. Q: You mentioned just earlier that you’re a Forensic

Chemical Officer/DNA Analyst Officer, is that
correct?

A: Yes, Fiscal.

6. Q: How long have you been employed with the PNP –

Crime Laboratory Office with such profession?

A: As a Forensic Chemical Officer, I have been

working at my office in Bulacan for almost 15 years
beginning 2005 up to this present. On the other hand,
I have been working as a DNA Analyst in the same
office since 2010 or for almost 10 years.

7. Q: As a Forensic Chemical Officer, what are your

duties and responsibilities?

A: The following are my duties and responsibilities:

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 a.) Examination of the fingerprints including the
determination of its identity;
b.) Checking on the Tenprint Database and Latent to
Print Inquiries. The Latent print Database is used to
check if the arrested suspect has committed a previous
crime;
c.) Checking if the collected Latent print match with
another unsolved crimes;
d.) Retrieval of the images of candidate fingerprints
are retrieved from the Fingerprint Image Database and
displayed on the fingerprint workstation;
e.) Verification of the fingerprint and latent prints
which are stored on i-storage disk;
f.) Evaluate and review reports of other forensic
examiners; and
h.) Appear and testify in courts and other quasi-
judicial bodies as an expert technical witness.

8. Q: And as a DNA Analyst, what are your duties and

responsibilities?

A: The following are my duties and responsibilities:

a.) To analyze the evidence from the crime scenes for

the purpose of connecting it to a suspect or victim, the
evidence of which may include blood, bodily fluids,
or hair follicles;
b.) To develop the DNA Profiles from the samples;
and
c. ) To perform routine maintenance checks for
laboratory equipment, as well as quality control
checks;
d.) Appear and testify in courts and other quasi-
judicial bodies as an expert technical witness.

Prosec. Gonzales: Your Honor, before I proceed, I respectfully move

that the witness on stand, Redjina De Leon-Reyes be declared as
qualified as an expert witness in the field of Forensic Medicine on the
ground of her testimonies and identified documents prior to this instant
Motion.

9. Q. Now, Expert Witness, why are you here?

A: I am here because I was called by the Public

Prosecutor to testify or to give my expert opinion to
prove the following: (1) the blood sample taken from
the tip part of the subject bottle, from bed sheet and
from the bed cover is the blood of the Private
Complainant; and (2) the fingerprints taken from the
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 tip and lower part of said subject bottle are
conclusively matched to persons named, Armando
Estevez and Elizabeth Zaragosa.

10. Q: Since you mentioned two purposes, may I first go

to your first purpose which is about the subject blood
in this instant case?

A: Yes Fiscal.

11. Q: Expert Witness, you mentioned a while ago that

you are here to prove that the blood sample taken
from the subject bottle is the blood of the Private
Complainant, is that correct?

A: Yes, Fiscal.

12. Q: How do you say so?

A: Because I performed a DNA Test to say that the

blood taken from the bottle, from the bed sheet and
from the bed cover is, indeed, Private Complainant’s
blood.

13. Q: What caused you to perform DNA Test?

A: On December 29, 2019, PCPL Love Hernandez

arrived and requested our office to perform a DNA
Test between the blood clotted on the tip of the bottle
as well as from the bed sheet and bed cover and the
blood to be taken from the Private Complainant
herself. Thus, she presented to me a Request Letter.

14. Q: I am now going to show to you a document,

purporting to be the Request Letter, can you please
identify the same?

A: Yes, Fiscal. This is the Request Letter that PCPL

Love Hernandez has presented to me.

Prosec. Gonzales: Your Honor, may I manifest that this Request Letter
dated December 29, 2019, as was just identified by the expert witness,
was already marked during the Pre-Trial Conference as our Exhibit
“__”.
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 15. Q: You mentioned a while ago about a bottle, bed
sheet, and bed cover, what are these?

A: When PCPL Love Hernandez requested our office

to perform a DNA Test, I received from her this one
(1) bottle of San Miguel Beer (San Mig Light)
marked as “LH-1 12292019”, one (1) bed sheet
marked as “LH-2 12292019”, and one (1) bed cover
marked as “LH-3 12292019”, each of which has a
signature affixed beside said marking.

16. Q: I am now going to show to you pictures,

purporting to be of such one (1) bottle of San Miguel
Beer (San Mig Light) marked as “LH-1 12292019”,
one (1) bed sheet marked as “LH-2 12292019”, and
one (1) bed cover marked as “LH-3 12292019”, are
these the same objects you were referring to us?

A: Yes, Fiscal.

Prosec. Gonzales: Your Honor, may I manifest that these pictures

showing the subject one (1) bottle of San Miguel Beer (San Mig Light),
one (1) bed sheet, and one (1) bed cover, as were just identified by the
witness, were already compared with its respective actual objects and
were already marked during the Pre-Trial Conference as our Exhibits
“__”, “__”, and “__”, respectively.

17. Q: How did you receive these three objects from

PCPL Love Hernandez?

A: I received said objects immediately after I signed a

Transmittal Form, to acknowledge the receipt of said
bottle.

18. Q: I am now to show to you a document, purporting to

be a Transmittal Form, is this the Transmittal Form
you were referring to us?

A: Yes, Fiscal.

Prosec. Gonzales: Your Honor, may I manifest that this Transmittal

Form, as was just identified by the witness, was already marked during
Pre-Trial Conference as our Exhibit “__”.

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 19. Q: After you received such objects, what did you do
next, if any?

A: I immediately performed DNA Test the procedure

of which is already provided in my DNA Analysis
Report.

20. Q: I am now showing to you a document, purporting

to be a DNA Analysis Report, is this the same
document you were referring to us?

A: Yes, Fiscal.

Prosec. Gonzales: Your Honor, may I manifest that this DNA Analysis
Report, as was just identified by the witness, was already marked during
the Pre-Trial Conference as our Exhibit “__”.

21. Q: I noticed that there is a signature affixed over a

name of Redjina De Leon-Reyes, whose signature is
this?

A: That’s my signature, Fiscal.

Prosec. Gonzales: Your Honor, may I manifest that the signature over
the name of Redjina De Leon-Reyes at the last page of this DNA Analysis
Report, as was just identified and confirmed to be the witness’ signature,
was already bracketed and marked during the Pre-Trial Conference as
our Exhibit “__”.

22. Q: In what page of this DNA Analysis Report we can

found the procedure you conducted in DNA Test?

A: You can find it at page 2 to 3 of my report.

Prosec. Gonzales: Your Honor, may I manifest that the procedure

followed by the expert witness, provided in the 2nd and 3rd page of her
DNA Analysis Report, was already bracketed and sub-marked during
the Pre-Trial Conference as our Exhibit “ __”.

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 23. Q: After you conducted DNA Test in accordance with
the procedure provided in your DNA Analysis Report,
what is your finding/s or result/s?

A: My results and findings are already provided at the

3rd page of my DNA Analysis Report.

Prosec. Gonzales: Your Honor, may I manifest that the Results and
Findings by the expert witness, provided in the 3 rd page of her DNA
Analysis Report, was already bracketed and sub-marked during the Pre-
Trial Conference as our Exhibit “ __”.

24. Q: What can you say about your results and findings,
Mrs. Witness?

A: My results and findings are already provided at the

4th page of my DNA Analysis Report.

Prosec. Gonzales: Your Honor, may I manifest that the Conclusion by

the witness, provided also in the 4th page of her DNA Analysis Report,
was already bracketed and sub-marked during the Pre-Trial Conference
as our Exhibit “ __”.

25. Q: Now, Mrs. Witness, we can move now to your

second purpose which is about that the fingerprints
taken from the tip and lower part of said subject bottle
are conclusively matched to persons named, Armando
Estevez and Elizabeth Zaragosa, is that correct?

A: Yes, Fiscal.

26. Q: How do you say so?

A: I said that because that is my findings when I

performed the Fingerprint Analysis.

27. Q: What caused you to conduct such analysis?

A: When I received the subject bottle on December

29, 2019, the duty officers, PCPL Love Hernandez
also requested our office, by virtue of a Request Letter
also to perform Fingerprint Analysis between the
fingerprint left, if any, on the subject bottle and
fingerprints to be secured by some other day.

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 28. Q: I am now going to show to you a document,
purporting to be a Request Letter, is this the same
Transmittal Form you were referring to us?

A: Yes, Fiscal.

Prosec. Gonzales: Your Honor, may I manifest that the Request Letter,
as was just identified by the witness, was already sub-marked during the
Pre-Trial Conference as our Exhibit “ __”.

29. Q: How do you conducted said Fingerprint Analysis?

A: After I conducted the DNA Test, I immediately

conducted the Fingerprint Analysis the procedure of
which is already provided in my Forensic Analysis
Report.

30. Q: I am now showing to you a document, purporting

to be a Fingerprint Analysis Report, is this the same
document you were referring to us?

A: Yes, Fiscal.

Prosec. Gonzales: Your Honor, may I manifest that this Fingerprint

Analysis Report, as was just identified by the witness, was already
during marked Pre-Trial Conference as our Exhibit “__”.

31. Q: I noticed that there is a signature affixed over a

name of Redjina De Leon-Reyes, whose signature is
this?

A: That’s my signature, Fiscal.

Prosec. Gonzales: Your Honor, may I manifest that the signature over
the name of Redjina De Leon-Reyes at the last page of this Fingerprint
Analysis Report, as was just identified and confirmed to be the witness’
signature, was already bracketed and sub-marked during the Pre-Trial
Conference as our Exhibit “__”.

32. Q: In what page of this Fingerprint Analysis Report

we can found the procedure you followed in
conducting Fingerprint Analysis?

A: You can find it at the 8th page of my report.

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Prosec. Gonzales: Your Honor, may I manifest that the Brief Concept of
CA Method, provided on the 8th page of her DNA Analysis Report, was
already bracketed and sub-marked during the Pre-Trial Conference as
our Exhibit “ __”.

33. Q: After the procedure provided in your Forensic

Analysis Report, what are your finding/s?

A: I found two series of fingerprints, one was taken

from the tip part of the subject bottle, while the other
one was taken from the lower part of the subject
bottle.

34. Q: What did you do next, if any?

A: The two series of fingerprints taken from the bottle

were properly photographed and the printed copy
were marked as “FT1200001-01” and “FT1200001-
02”, accordingly, and the same were saved in
Automated Fingerprint Identification System
Database.

35. I am showing to you pictures, purporting to be

containing fingerprints, are these the same fingerprints
you found out of the subject bottle?

A: Yes, Fiscal. This one is from the tip part of the

bottle, while the other one is from the lower part of
said bottle.

Prosec. Gonzales: Your Honor, may I manifest that the picture of one
fingerprint marked as “FT1200001-01” and the other one as
“FT1200001-02”, were already marked during the Pre-Trial Conference
as our Exhibits “ __” and “__”, respectively.

36. Q: How about the subject bottle, what did you do, if
any?

A: During that time, the fingerprints of the Accused

were not yet available, thus, I decided to immediately
place the subject bottle in a secured box which was
marked as “FT1200001-GLS01” for identification.
After which, I placed the box inside of a secured room
which I am only allowed to enter;
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 37. What happened next, if any?

A: After 24 days from receipt of the subject bottle, or

on January 22, 2020, PCPL Love Hernandez
approached our office and submitted four documents,
containing the fingerprint record of all the accused,
which I marked as “FT1200001-03”, “FT1200001-
04”, “FT1200001-05”, and “FT1200001-06”,
respectively, and I signed a Transmittal Form, as to
such receipt

38. Q: I am now showing to you documents, purporting to

be a Fingerprint Records of all the Accused as well as
the Transmittal Form, are these the same documents
you were referring to us?

A: Yes, Fiscal.

Prosec. Gonzales: Your Honor, may I manifest that the Fingerprint

Records of all the Accused which were marked as “FT1200001-03”,
“FT1200001-04”, “FT1200001-05”, and “FT1200001-06”, and the
copy of the Tranmittal Form as were just identified and by the witness’,
were already marked during the Pre-Trial Conference as our Exhibits
“__”, “__”, “__”,“__”, and “__”, respectively.

39. Q: Upon receipt of such Fingerprint Records of all the

Accused, what did you do next, if any?

A: I immediately initiated the process of ACE-V2

COMPARISON by comparing and identifying with
the saved series of Fingerprints from the Automated
Fingerprint Identification System Database I
mentioned earlier.

40. Q: What is this ACE-V2 COMPARISON?

A: I already provided in my report the brief concept of

ACE-V2 COMPARISON.

Prosec. Gonzales: Your Honor, may I manifest that the Brief Concept of
ACE-V2 Comparison, provided on the 8th page of her Fingerprint
Analysis Report, was already bracketed and sub-marked during the Pre-
Trial Conference as our Exhibit “ __”.

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 41. Q: After such analysis, what is your result/s and
finding/s?

A: My result and findings are already provided in the

9th to 10th page of my Fingerprint Analysis Report.

Prosec. Gonzales: Your Honor, may I manifest that the Findings by the
witness, provided on the 9th to 10th page of her Fingerprint Analysis
Report, was already bracketed and sub-marked during the Pre-Trial
Conference as our Exhibit “ __”.

42. Q: What did you do the, if any?

A: I approached my Administering Chief, Ervin John

Salcedo to review my findings, to which the latter
approved.

Prosec. Gonzales: Your Honor, may I manifest that the signature of

Administering Chief, Ervin John Salcedo on the 10th page of her
Fingerprint Analysis Report, was already sub-bracketed and sub-marked
during the Pre-Trial Conference as our Exhibit “ __”.

43. Q: What can you say about your findings, Mrs.

Witness?

A: My conclusion is already provided on the 11th page

of my report.

Prosec. Gonzales: Your Honor, may I manifest that the Conclusion by

the witness, provided on the 11th page of her Fingerprint Analysis
Report, was already bracketed and sub-marked during the Pre-Trial
Conference as our Exhibit “ __”.

AFFIANT FURTHER SAYETH NAUGHT.

IN WITNESS WHEREOF, I have hereunto set my hand this 24 th

day of February, 2020.
_____________________________
REDJINA DE LEON-REYES

SUBSCRIBED AND SWORN TO before me this 10th day of 24th

day of February, 2020. Affiant exhibiting to me his competent evidence
of identity, PRC License No. 124579SDA, issued on 2018 Aug 11, valid
until 2020 Aug 10.

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 Hon. Robin Ron Zafra-Mendoza
Asst. Provincial Prosecutor of Bulacan

Lawyer’s Attestation

I hereby certify that I faithfully recorded or caused to be recorded

the questions asked and the corresponding answers given by the witness.
I further certify that neither I nor any other person was present and/or
assisting the witness, much more, coached the latter with all his answers
to the questions propounded.

P. PROS. FRANCISCO JEREMIAH

SANTOS GONZALES

SUBSCRIBED AND SWORN TO before me this 24th day of

February, 2020 at Malolos City, Bulacan. Affiant exhibiting to me his
IBP Roll of Attorney I.D. with no. 63254 as competent evidence of his
identity.

Hon. Robin Ron Zafra-Mendoza

Asst.Provincial Prosecutor of Bulacan

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