REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

Seventh Judicial Region
Branch 101
Cebu City

PEOPLE OF THE PHLIIPPINES,

Plaintiffs

CRIM CASE NO. CEB-C-1123

versus
For: LIBEL

RIZAL FAJARDO,
Accused.
x--------------------------------------x

FORMAL OFFER OF DOCUMENTARY EXHIBITS

Private Complainant, through counsel, respectfully files

this FORMAL OFFER OF EVIDENCE for marking and admission of
the following:

EXHIBIT DOCUMENT PURPOSE

A The Universal Serial To prove the existence of that
Bus (USB) or Flash segment of the radio program
Drive containing the “Reklamo Publiko” wherein the
recorded video of the defamatory and malicious
program “Reklamo statements against the private
Publiko” complainant were uttered.
A-1 The Sworn Affidavit of To prove that the same program
Ms. Annelia Villaflores “Reklamo Publiko” was also aired
Pepito of SkyCable and broadcasted over the
Corporation in relation television and that the recorded
to the recorded video video is authentic and came from a
legitimate source whose nature of
business involves the recording of
programs in the ordinary course of
business.
B Judicial Affidavit of To prove that the accused
Sulpicio Gonzales Sr. committed the crime of Libel by
 making defamatory remarks
against the private complainant
over the radio through his
malicious imputations which
included matters not anymore
related to the latter’s function as a
public official.
B-1 The signature of To prove the truthfulness and
Sulpicio Gonzales Sr. veracity of the judicial affidavit
filed by the private complainant as
well as the fact that he was the
one who actually and voluntarily
executed the document based on
his personal knowledge.
C Judicial Affidavit of To prove the element of publicity
Cassandra Mondragon when the program was in fact
broadcasted over the radio and
was made available to public
listeners as well as to prove the
malicious utterances made by the
accused during that program.
C-1 The signature of To prove the truthfulness and
Cassandra Mondragon veracity of the judicial affidavit
filed by the witness as well as the
fact that she was the one who
actually and voluntarily executed
the documents based on her
personal knowledge.
D Endorsement Letter To prove that the utterances made
addressed to the Head by the accused regarding the
of Vicente Sotto alleged balance of twelve billion
Memorial Medical pesos (P12,000,000,000.00) from
Center the rehabilitation fund, which were
allegedly used by the private
complainant for his own benefit,
are malicious in that all allotments
under the private complainant’s
name were released directly to
Vicente Sotto Memorial Medical
Center and no government funds
whatsoever remained in the
custody of the private
complainant.
E Certificate from DBM To prove that the utterances made
dated 2010 by the accused regarding the
alleged twenty billion pesos
 (P20,000,000,000.00)
rehabilitation fund are malicious
in that only seventy-million
(P70,000,000.00) pesos were
allotted to the private complainant
for the year 2010 with the
corresponding Notice of Cash
Allocation given to Vicente Sotto
Memorial Medical Center.
F Certificate from DBM To prove that the utterances made
dated 2013 by the accused regarding the
alleged twenty billion pesos
(P20,000,000,000.00)
rehabilitation fund are malicious
in that no public funds were
allotted to the private complainant
for the year 2013.
G Certificate from DBM To prove that the utterances made
dated 2019 by the accused regarding the
alleged twenty billion pesos
(P20,000,000,000.00)
rehabilitation fund are malicious
in that no public funds were
allotted to the private complainant
for the years 2013 to 2019.
H Court Clearance issued To prove that the words “kawatan”,
by the Office of the “mangamang”, and “mandurugas”
Clerk of Court of the uttered by the accused have
Regional Trial Courts publicly and maliciously imputed a
Cebu City crime against private complainant
because in truth and in fact there
were no existing cases filed against
the latter for Malversation,
Election Offenses, and R.A. 9165
violations, or for any other crimes.
I General Appropriations To prove that the utterances made
Act as of 2018 showing by the accused regarding the
the amount alleged twenty billion pesos
appropriated to the (P20,000,000,000.00)
House of Congress, rehabilitation fund are malicious
particularly the House in that such amount is even more
of Representatives than the total amount actually
appropriated to the House of
Representatives.

PRAYER
 WHEREFORE, it is most respectfully prayed of this Honorable
Court to admit the foregoing documentary exhibits for the purposes
they are each offered.

Cebu City, Philippines, September 14, 2019.

BABA MEPA JAGIDO LAW FIRM

Counsel for the Private Complainant
Fuente Rotonda, Cebu City
Telephone No. (032) 262-0081
Email Add: maryannelaw@gmail.com

By:

ATTY. MARY ANNE B. JAMISOLA

Roll No. 88899
PTR No. 123456 Feb 14, 2019 Cebu City
IBP Lifetime No. 1234567 Cebu City Chapter
MCLE Compliance No. VII-01234232

Copy furnished:

The Honorable Public Prosecutor

Cebu City
By personal service: Received by: __________________________

VVE PLLaSa Law Office

Counsel for the Accused
305-A 3rd flr., Medalle Building,
Osmena Boulevard, Cebu City
By personal service: Received by: ___________________________