Formal Offer Exhibits

Download as doc, pdf, or txt
Download as doc, pdf, or txt
You are on page 1of 3

Republic of the Philippines

MUNICIPAL TRIAL COURT IN CITIES


11th Judicial Region
Branch 4, Davao City

THE PEOPLE OF CRIM. CASE NOS. 124,123-D-06


THE PHILIPPINES to 124,125-D-06

---versus---
FOR: DIRECT ASSAULT UPON AN
MYRNA M. TORRES, ET AL., AGENT IN AUTHORITY AND TWO
Accused. (2) COUNTS OF GRAVE SLANDER.
__________________________________________________________

FORMAL OFFER OF EXHIBITS

COME NOW both Accused, through the undersigned counsel, unto


this Honorable Court, most respectfully submits/offers the following
documentary exhibits, to wit:

EXHIBIT “1” as well as its sub-markings: Police Record of Event


dated March 15, and 2006 timed 13:15.

PURPOSE/S : The above exhibit is offered to prove that we informed


the responding policeman that it was Barangay Captain Escasinas
who went to our house and that it was she who shamed and harassed
us on March 15, 2006.

It is also being offered as part of the testimonies of Myrna M.


Torres and Joel G. Alforo.

EXHIBIT “2” as well as its sub-markings: Police Record of Event


dated March 15, 2006, and timed 14:11.

PURPOSE/S : The above exhibit is offered to prove that Myrna


M. Torres was asked by a policeman at the Sta. Ana Police Station
the reason we they were there, and when she told him why, he told
them that it would be better if they would also put on record
their complaint against Barangay Captain Escasinas, and that they
followed his advice.
---Page Two---

It is also being offered as part of the testimonies of Myrna M.


Torres and Joel G. Alforo.

EXHIBITS “3” and “4” as well as its sub-markings: Two (2) Medical
Certificates both dated March 18, 2006 which will prove that
both Accused were admitted at San Pedro Hospital of Davao City
as a result of the said incident.

PURPOSE/S : The above exhibit is offered to prove that


Private Complainant abused her authority to harass both accused
persons by influencing the police that when both accused got back
at the police station, they were informed by the police that they
would be put inside the detention cell, and because of too much
sadness and fear why it is happening to them, accused
Ferdinand M. Torres vomited due to hypertension , and accused Myrna
M. Torres likewise fainted. That because of this, they were brought and
confined at the San Pedro Hospital of Davao City.

It is also being offered as part of the testimonies of Myrna M.


Torres and Joel G. Alforo.

EXHIBIT “5” as well as its sub-markings: Contract of Legal Services


dated January 2, 2013.

PURPOSE/S : The above exhibit is offered to prove that on


January 2, 2013, accused persons secured the services of ATTY. BEHN
JOSEPH O. TESIORNA, with an agreed Attorney’s Fee of P100,000.00,
plus an appearance fee of P3,000.00 per court hearing.

It is also being offered as part of the testimonies of Myrna M.


Torres and Joel G. Alforo.

With the eventual admission of all these documentary exhibits,


Defense rests their case.

Davao City, Philippines, September 11, 2018.


---Page Three---

ATTY. BEHN JOSEPH O. TESIORNA


(Counsel for the Accused)
MCLE Compliance No. V-0009928/05-13-2015
Roll No. 46672
IBP Lifetime No. 014228/08-31-2017
PTR No. 0057720C/01-09-18/Davao City
TESIORNA, GONZALES & Associates Law Offices
Suite 202, Villa Abrille Building
Ramon Magsaysay Avenue, Davao City

CC : ATTY. RANOELO C. LEONAR


(Private Prosecutor)

You might also like