Republic of the Philippines

National Capital Judicial Region

REGIONAL TRIAL COURT
Branch 57, Makati City

PEOPLE OF THE Criminal Case No.17-12345

PHILIPPINES, For: Violation of Art 248 of the
Complainant, Revised Penal Code for the crime of
Murder
-versus-

JUAN TED y BALISONG,

Accused.
x-------------------------------x

FORMAL OFFER OF EVIDENCE

Prosecution, through undersigned counsel and unto this Honorable

Court, most respectfully offers its documentary and object evidence as
follows:

Exhibit Description Purpose

A “Sinumpaang Salaysay ng To prove:
Pag-aresto” of SPO1 Nica 1. The fact of death of the
Pasa (original and attached victim;
herewith) 2. The time and place of the
A-1 Signature of SPO1 Nica Pasa incident;
in her “Sinumpaang 3. The circumstances
Salaysay ng Pag-aresto” surrounding at the time of
(original and attached the incident;
herewith) 4. The arrest of the accused
B Judicial Affidavit of SPO1 Juan Ted Y Balisong;
Nica Pasa (original and 5. To identify and
attached herewith) authenticate the weapon
B-1 Signature of SPO1 Nica Pasa used in the killing of the
in her Judicial Affidavit victim; and
(original and attached 6. Such other purposes
herewith) stated in the Judicial
Affidavit.

C “Sinumpaang Salaysay ng To prove:

Pag-uulat” of Anna Carmela 1. The fact of death of the
G. Virtucio (original and victim;
attached herewith)
C-1 Signature of Anna Carmela 2. The time and place of the
G. Virtucio in her incident;
“Sinumpaang Salaysay ng 3. The circumstances
Pag-uulat” (original and surrounding at the time of
attached herewith) the incident;
D Judicial Affidavit of Anna 4. The motive of Accused
Carmela G. Virtucio Juan Ted Balisong to kill
(original and attached the victim;
herewith) 5. The crime was committed
D-1 Signature of Anna Carmela by Accused Juan Ted
G. Virtucio in her Judicial Balisong;
Affidavit (original and 6. The witness was able to
attached herewith) personally identify
Accused Juan Ted
Balisong; and
7. Such other purposes
stated in the Judicial
Affidavit
E Certificate of Death of Pedro To prove the fact of death of
P. Penduko (faithful Victim Pedro P. Penduko
reproduction of the original
and marked as E in the
records of the Honorable
Court)
F Knife (faithful reproduction To prove the weapon used in
of the original and marked the killing of the victim
as F in the records of the
Honorable Court)

2
 PRAYER

WHEREFORE, foregoing premises considered, Petitioner prays for all

of the abovementioned exhibits to be admitted as evidence for the purposes
they are being/have been offered and for other purposes that the Honorable
Court may deem just and proper under the premises.

Petitioner likewise prays for other reliefs which this Honorable Court
may find just and equitable under the circumstances.

Makati City for Quezon City, 11 July 2018.

MELIZA VICTORIA S. ARIAS

City Prosecutor
16th Floor, New Makati City Hall, F Zobel Street, Makati City
Telephone No.: 899 8668
IBP No. 498464, Makati City, 03 January 2018
PTR No. 876535, Makati City, 03 January 2018
Roll No. 696432;
MCLE Compliance No. V-00045; 01 April 2015

Copy Furnished:

JUAN TED BALISONG

Accused

Thru:

INDAY BOTE
Makati City Jail
Lawton Ave., Makati City

ATTY KEVIN CLELO

Defense Counsel
987 Amorsolo St., Legaspi Village
Makati City