REPUBLIC OF THE PHILIPPINES

National Judicial Capital Region

REGIONAL TRIAL COURT
Branch___
PASAY CITY

MILES L. DELA ROSA, rep. by

her mother,
ANNA PAMELA DELA ROSA,
Complainant,

Criminal Case No. 04-124

For: RAPE
-versus-

REGINALD ARCEO and

EARVIN JAMES ATIENZA,
Accused.
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FORMAL OFFER OF DOCUMENTARY EVIDENCE

PLAINTIFF by the undersigned counsel and unto this Honorable

Court, most respectfully offers the following documentary and exhibits for
the above titled case, to wit:

EXHIBITS DESCRIPTION PURPOSE/S

“A” Complaint Affidavit of  To prove the fact that the crime

Ms. Libres Miles Dela has been committed by the
Rosa. accused.

“A-1” Signature of Ms.  To prove that the victim duly

Libres Miles Dela executed the affidavit (Exh. “A”).
Rosa.
“B” Joint Affidavit of Ms.  To corroborate the testimony of
Angelie Pua and the first witness;
Audrey Gusi.  To testify to the truth of the
affidavit executed;
 To attest to the incident pertaining
to the commission of the crime of
rape by the accused;
 To prove the fact of the crime
charge against the accused; and
 To establish the circumstances
surrounding the commission of the
crime.

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“B-1” Signature of Ms.  To prove that the witness duly
Angelie Pua and executed the affidavit (Exh. “B”).
Audrey Gusi.
“C” Medical Examination  To prove that the Complainant,
Report prepared and upon examining made by the
signed by Dr. Cellini expert witness, was found to be
Arenas, M.D. suffering from vaginal laceration,
contusion.

“C-1” Signature of Dr.  To prove that the witness duly
Cellini Arenas, M.D. executed the Medicolegal Report
(Exh. “C”).
“D” to “E 1- Crime scene picture of  To provide the court information
6” the body of the victim as to the physical condition of the
victim.
“F” Crime Scene  To provide the court information
underwear of the as to the circumstance of the
victim victim;
 To corroborate the testimony of
the primary witness presented.

“G” Information prepared  To provide the court information

and executed by pertaining to the commission of
(SGD) SPO2 RAMON the crime of rape by the accused.
GICOS.
“G-1” Signature of (SGD)  To prove that the witness duly
SPO2 RAMON executed and prepared the
GICOS. Information. (Exh. “G”)

Aforesaid exhibits are being offered to prove that the crime and
accusation against the accused was true and committed at the address
indicated in the Complaint.

WHEREFORE, premises considered, it is most respectfully prayed to

this Honorable Court that the foregoing object and documentary exhibits be
admitted for which each and all said exhibits were offered in proving the
claims of the complainant/s and with the formal submission of the
aforesaid coupled with the testimonies of the witness who testified thereon.

Pasay City.
November 9, 2018

KENT WILSON ANDALES

Assistant City Prosecutor

NOTICE

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The Hon. Clerk of Court
RTC Branch ___ Pasay City

GREETINGS:

Please submit the foregoing Formal Offer for the consideration and
approval of the Honorable Court immediately upon receipt thereof.

KENT WILSON ANDALES

Assistant City Prosecutor

Copy Furnished:

Counsel for the Accused

EXPLANATION

Copies of the foregoing Formal Offer are served upon counsel of the
accused and filed with the Court by personal service.

KENT WILSON ANDALES

Assistant City Prosecutor

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