Republic of the Philippines

SIXTH JUDICIAL REGION

REGIONAL TRIAL COURT
SAN CARLOS CITY, NEGROS OCCIDENTAL
BRANCH 59
-oOo-

PEOPLE OF THE PHILIPPINES,

Complainant, CRIM CASE No.RTC-19-7646

- Versus- Violation for Sec. 5,

and
JULY HOMECILLO y ENCINA Sec. 11, 2nd Paragraph
Accused. No. 3, Art. II of RA 9165
X—----------------------------------------x

FORMAL OFFER OF EXHIBITS

The undersigned Prosecution Attorney to this Honorable Court, respectfully

states:

1. That during the hearing of this case on 22 June 2022, this

representation moved in open court to submit his Formal Offer of
Exhibits in writing;

2. His motion was granted giving him fifteen (15) days within which to
submit his formal offer of exhibits;

3. Hence, this submission, to wit:

EXHIBITS DESCRIPTION PURPOSE/S

Exh. “A” Page 1 of the Affidavit of To prove the following:

the Poseur Buyer/Seizing a.) The existence and
Officer due execution of the
affidavit on its Page 1;
b.) The veracity and the
truthfulness of the
affidavit;
c) The material
allegations in the
information are true
d.) To form an integral
part of the direct
testimony of PSsg
Michael Tuazon;
e.) To prove that PSsg
Tuazon is the poseur
buyer/seizing officer.

Exh. “A-1” Page 2 of the Poseur To prove the following:

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 Buyer/Seizing Officer a.) The existence and
due execution of the
affidavit on its Page 2;
b.) The veracity and the
truthfulness of the
affidavit;
c) The material
allegations in the
information are true;
d.) To form an integral
part of the direct
testimony of PSsg
Michael Tuazon;
e.) To prove that PSsg
Tuazon is the poseur
buyer/seizing officer.

Exh. “A-2” Page 3 of the Affidavit of a.) The existence and

the Poseur Buyer/Seizing due execution of the
Officer affidavit on its Page 3;
b.) The veracity and the
truthfulness of the
affidavit;
c) The material
allegations in the
information are true;
d.) To form an integral
part of the direct
testimony of PSsg
Michael Tuazon;
e.) To prove that PSsg
Tuazon is the poseur
buyer/seizing officer.

Exh. “A-3” The signature and name a.) The existence and
of the affiant of the due execution of the
aforementioned affidavit affidavit where the
signature and name of
the affiant appear;
b.) The veracity and the
truthfulness of the
affidavit;
c) The material
allegations in the
information are true;
d.) To form an integral
part of the direct
testimony of PSsg
Michael Tuazon;
e.) To prove that PSsg
Tuazon is the poseur
buyer/seizing officer.

Exh. “B” One (1) heat sealed a.)To prove the existence
transparent plastic of a drug specimen as
sachet of suspected an evidence being the
shabu marked as item handed to PSsg

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 “JEH-BBI” Tuazon during the
buybust operation;
b.) To prove that a sale
had been consummated
since such drug
specimen had already
been handed to PSsg
Tuazon.

Exh. “C” One (1) heat sealed a.) To prove the

transparent plastic existence of a drug
sachet of suspected specimen as a result of
shabu marked as an incidental search after
“JEH-1” the lawful arrest found in
the right front pocket of
the accused’s short
pants;
b.) To prove that such
drug specimen was duly
marked as part of
evidence.

Exh. “C-1” One (1) heat sealed a.) To prove the

transparent plastic existence of a drug
sachet of suspected specimen as a result of
shabu marked as an incidental search after
“JEH-2” the lawful arrest found in
the right front pocket of
the accused’s short
pants;
b.) To prove that such
drug specimen was duly
marked as part of
evidence.

Exhibit “D” Five Hundred Peso Bill a.) To prove the

(Php 500.00) used as a existence of a buy bust
buy-bust money with money found on the
serial number GU101251 back right pocket of the
marked as “JEH-BBM” accused’s short pants;
b.) To serve as an
evidence that a sale had
already been
consummated

Exhibit “E” Request for Laboratory a.) To prove the

Examination existence and due
execution of the
document

Exhibit “E-1” Stamp with the name a.) To prove the

and signature of PSSG existence of Request for
DELA CRUZ Laboratory Examination
that was personally
received by PSSG DELA
CRUZ;

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Exhibit “F” Chemistry Report No. a.) to prove the
D-263-2019 existence and due
execution of the Result
of the Crime Laboratory

Exhibit “F-1” Drug Specimens a.) To prove that the

Submitted same drug specimens
recovered during the
buy-bust and incidental
search after the arrest
were the same evidence
submitted for
examination in crime
laboratory
b.) to prove its existence
and in accordance to the
chain of custody

Exhibit “F-2” Findings to prove the POSITIVE

result for the presence of
Methamphetamine
hydrochloride, a
dangerous drug;

Exhibit “F-3” The name and to prove the chemistry

signatureof the Forensic report’s existence and
Chemist due execution

Exhibit “G” Inventory Receipt of a.)to prove its existence

Seized Items and due execution
b.) to prove that the
seizure of items were
properly inventoried for
it’s chain of custody

Exhibit “H” Extract Copies from the To prove the existence of

Police Blotter such document wherein
the incident was
documented

Exhibit “H-1” Name and Signature of To prove the existence

Rocky Q. Desear and due execution of the
Police Blotter Report

Exhibit “I” Coordination Form To prove the existence of

such for the buy-bust
operation

Exhibit “I-1” Name and Signature of To prove existence and

the Team Leader, PSMS due execution of
Rodillo Taganile Coordination Form

Exhibit “I-2” Name and Signature of To prove existence and

the Head of Office, due execution of
PMAJ Rocky Q. Desear Coordination Form

Exhibit “I-3 Stamp of PDEA 6 To prove that such

coordination form had

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 been received by PDEA
6

Exhibit “J” Pre-operation Report To prove the existence of

the document in support
to the Busy Bust
Operation

Exhibit “J-1” Name and Signature of To prove the existence

PMAJ Rocky Q Desear and due execution of the
Pre-operation Report

Exhibit “J-2” Stamp of PDEA 6 To prove that such

Pre-operation report had
been received by PDEA
6

Exhibit “K” Investigation Report To prove its existence as

the basis of the
complaint filed

Exhibit “K-1” Name and Signature of To prove the existence

Rocky Q Desear and execution of the
Investigation Report

Exhibit “L-1” Pictures while To prove the existence

conducting Initial and due execution of
Marketing Onsite markings on the pieces
of evidence recovered

Exhibit “L-2” Pictures while To prove the existence

conducting proper and due execution of the
inventory propriety of the inventory
on the pieces of
evidence recovered

Exhibit “L-3” Picture of the Buy-Bust To prove the existence of

Money the buy-bust money
appearing therein its
serial number

Exhibit “L-4” Picture of the Drug To prove the existence of

Specimens together with the drug specimens
the Buy-Bust Money recovered during the
buy-bust operation

Exhibit “M: Turn Over of Non-Drugs To Prove that the

Evidence Buy-Bust Money was
Properly turned over as
a piece of Evidence

Exhibit “M-1” Name and Signature of To prove that such

Elsa B. Monsale, buy-bust money was
Administrative Officer V received lawfully in OPP

Exhibit “N” Chain of Custody Form To prove that drug

of the Forensic Chemist specimens were handled
in accordance to the
Chain of Custody for the

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 preservation of the
sanctity of drug evidence

4. All the documentary evidence as exhibits were already submitted and

turned-over to the Honorable Court or to the Office of the Provincial Prosecutor,
as the case may be.

WHEREFORE, premises in the foregoing consideration, the undersigned

Prosecution Attorney prays that this Formal Offer of Exhibits be deemed
admitted.

Bacolod City, 28 June 2022.

Respectfully Submitted.

RE CHARLES P. TUPAS
Assisting Prosecution Attorney
Office of the Provincial Prosecutor - Negros Occidental
MCLE Compliance No. VII - 0005122
Valid until April 14, 2025

Atty. Cheysson A. Chavez

The Branch Clerk of Court
Regional Trial Court
Branch 59
San Carlos City

GREETINGS:

Please submit the foregoing formal offer of evidence immediately upon

receipt hereof for consideration of the Honorable Court.

RE CHARLES P. TUPAS

Cc:
Atty. Gamaliel E. Nardo
Public Attorney’s Office
San Carlos City