Republic of the Philippines

MUNICIPAL CIRCUIT TRIAL COURT

CAMALIGAN-GAINZA-MILAOR, CAMARINES SUR
5th Judicial Region
CAMALIGAN, CAMARINES SUR

PEOPLE OF THE PHILIPPINES

Complainant,

- versus - Crim Case No. 3563

For: GRAVE COERCION
VICTOR B. BAL JR
Respondent
x-------------------------------------------------------------------------------------------------x

FORMAL OFFER OF DOCUMENTARY EXHIBITS

The undersigned counsel for the COMPLAINANT, and unto this Honorable
Court, most respectfully submits and thereby offers, the following documentary
exhibits stating the purposes for which they are respectively offered, to wit:

Documentary Exhibit Purpose/s

Exhibits A to A-1 – 1. To prove that the subject vehicle which is

Certificate of Registration
and Official Receipt-
found on page 33 of the
court’s records (faithful
reproduction as compared
with the original)
Toyota Revo with plate no. XJW433 is
registered under the name of David M.
Madrid;
2. That it is the same vehicle subject of the
lease contract between David Madrid and
Milaor Trading Corporation (“MTC”, for
brevity) represented by Dennis Tan;
3. To prove that accused Victor Bal is not the
lawful owner and/or the registered owner
of the Toyota Revo
4. To form part of Dennis Tan’s testimony

Exhibits B to B-4- 1. To prove that David M. Madrid and MTC

Lease Contract of Motor
Vehicle
found on pages 34-38 of
the court’s records (faithful
reproduction as compared
with the original)
represented by Dennis C. Tan entered into
a lease contract of motor vehicle which is
the Toyota Revo with plate no. XJW433 for
a period of one year, from January 1, 2019
to December 31, 2019
2. That upon expiration of the lease, MTC, the
lessee, shall return the subject vehicle to

Exhibits C to C-2-
MTC Letter dated January
08, 2022
found on pages 39-41 of
the court’s records (faithful
reproduction as compared
with the original)
Exhibits D to D-2-
Photographs of Vehicle
found on page 150 of the
court’s records
Exhibits E to E-2-
Compact discs containing
video recordings
found on page 55 of the
court’s records
David Madrid.
3. To form part of Dennis Tan’s and Rey
Dulpina’s testimonies
1. To prove that on January 8, 2020, accused
Victor Bal received a copy of a letter from
MTC demanding from Victor Bal to
immediately turn-over the Toyota Revo
together with other personal properties
listed therein.
2. That in said letter, Victor Bal sent a text
message informing MTC of his resignation
effective September 30 and thus, Dennis
Tan, MTC President, personally talked with
Bal about his resignation.
3. To prove that MTC has accepted his
resignation and Bal was requested to stay
until December 31, 2019 for proper
turnover and for MTC to find his
replacement.
4. That despite receipt of said letter, Bal did
not return the Toyota Revo and all other
properties in his custody
5. To form part of Dennis Tan’s and Rey
Dulpina’s testimonies
1. To prove that the Toyota Revo was still in
the possession of Victor Bal even after his
employment and after repeated demands.
2. That the pictures were taken on January 10,
2020 and the motor vehicle was parked
outside the premises of MTC, despite
demands that it be returned already.
3. To form part of Dennis Tan’s testimony.
1. To prove that after receipt of the formal
letter of demand dated January 8, 2020,
another formal oral demand was made on
January 09, 2020 which were then recorded
and saved in a compact disc
2. That witness Dennis Tan was present when
these video recordings were saved and
MTC employees namely Chariza Olivares
and Rey Duplina were demanding the
return of the Toyota Revo as it was only

Exhibit G- Summons from
NLRC dated January 28,
2020 (page 151-152)
Exhibit J- Complaint of Bal
with NLRC (page 23)
(faithful reproduction as
compared with the original)
Exhibit H- Notice of
Conference (page 21)
Exhibit I- SeNA from NLRC
(page 22)
(faithful reproduction as
compared with the original)
Exhibit K- Minutes of
Conference during SENA
(page 24)
(faithful reproduction as
compared with the original)
Exhibit L- Minutes of
issued by reason of his employment.
3. To form part of Dennis Tan’s and Rey
Dulpina’s testimonies
1. To prove that accused Bal filed a labor case
for illegal dismissal before the NLRC and
Dennis Tan was ordered to appear for a
mandatory conference before the NLRC Sub
Arbitration Branch V
2. To prove that Bal caused the filing of the
labor case as form of a blackmail so that
MTC will be forced to settle before the
NLRC.
3. That the NLRC case was filed after Madrid
and Tan went to the Prosecutor’s Office to
file a criminal case for Carnapping against
Bal
4. To prove that the filing of the labor case
was made after David Madrid filed a
carnapping case against Bal on January 13,
2022.
5. To form part of Dennis Tan’s testimony.
1. To prove that after repeated demands to
Bal that he return the Toyota Revo, Dennis
Tan received a Notice of Conference and
SENA form inviting him for a conciliation-
mediation before the NLRC Sub Arbitration
Branch V on January 23, 2020
2. To form part of Dennis Tan’s testimony.
1. To prove that MTC through Dennis Tan,
Chariza Olivares attended the SENA
Conference and Bal initially agreed to
return the service vehicle. However, Bal
again refused to turnover the same.
2. To prove that on January 23, 2020, Bal was
still in possession of the Toyota Revo
despite repeated oral and written demands.
3. To form part of Dennis Tan’s testimony.
1. To prove that MTC through Dennis Tan,
Chariza Olivares attended the mandatory
Proceedings (page 25)
(faithful reproduction as
compared with the original)
Exhibit N to N-1 - Affidavit
of Dennis Tan (pages 37-38)
Exhibit O – Text Message
(faithful reproduction as
compared with the original)
Exhibit P – Judicial Affidavit
of Dennis C. Tan
conference on February 19, 2020 and it was
only in the afternoon of Feb 19, 2020 when
Bal turned over the Toyota revo to MTC.
2. To prove that Bal caused the filing of the
labor case as form of a blackmail so that
MTC will be forced to settle before the
NLRC.
3. To prove that on Feb 19, 2020, Bal was still
in possession of the Toyota Revo despite
oral and written repeated demands.
4. To form part of Dennis Tan’s testimony.
1. To prove that on January 13, 2020, Dennis
Tan executed an Affidavit in support to
David Madrid’s complaint for carnapping as
David Madrid had been continuously asking
from him the return of the Toyota Revo as
the lease contract had expired.
2. That Dennis Tan had also been asking the
return of the Toyota Revo from accused Bal
however the latter unlawfully possessed
the vehicle, and instead, filed a labor case
as form of blackmail.
3. To form part of Dennis Tan’s testimony.
1. To prove that accused Bal texted Dennis
Tan where Bal intimidated Dennis Tan as he
told the latter that he should be ashamed
on how he compensate his employees and
accused Bal is not returning the car and all
the things without proper turnover.
2. To form part of Dennis Tan’s testimony.
1. This shall constitute the direct examination
of witness Dennis Tan and it is being
submitted according to the purposes to
which it was offered during the
presentation of witness Tan on trial, such
that Bal committed the crime of Grave
Coercion when he withheld the possession
of the Toyota Revo and all other properties
when all of these were all issued to him
only by reason of his employment which

Exhibit Q– Judicial Affidavit
of Rey Dulpina
ended on December 31, 2019.
1. This shall constitute the direct examination
of witness Rey Dulpina and it is being
submitted according to the purposes to
which it was offered during the
presentation of witness Dulpina on trial,
such that Bal intimidated insulted and
shouted at him when he repeatedly
demanded from Bal the return of the
Toyota Revo and even shouted at him,
“Purbaran mo, Kakastahan taka.”

WHEREFORE, premises considered, it is most respectfully prayed of this

Honorable Court that this formal offer of exhibits be noted and given due course;
thus, the foregoing documentary exhibits be admitted for the purposes which
they are here respectively offered. Other reliefs and remedies under the premises
are likewise prayed for.

October 7, 2022, Naga City, Camarines Sur

SALES, CASTILLO and ASSOCIATES

Counsel for Private Complainant
2/F DECA Corporate Center
Panganiban Drive, Naga City
Tel. No. (054) 472-5664

By:

VITO GERARDO R. SALES

Copy Furnished

ATTY. ROMEL CASTRO

Public Attorney’s Office,
J. Miranda Ave Naga City

Explanation: Copy of this pleading had been sent to the parties through registered
mail due to distance, lack of time and unavailability of office personnel making
personal service impractical and inconvenient.

VITO GERARDO R. SALES