Republic of the Philippines

9th Judicial Region

REGIONAL TRIAL COURT
Branch 24
Ipil, Zamboanga Sibugay
-oOo-

PEOPLE OF THE PHILIPPINES, Criminal Case No.I-4920

Plaintiff,

-versus - - for -

TONG AFDAL NANDANG VIOL. OF SEC. 5, RA 9165

ABDULKARIM, ET. AL.,
Accused.
x--------------------------------------------------/

FORMAL OFFER OF EVIDENCE

THE STATE, thru the undersigned Associate Prosecution Attorney II
for the Province of Zamboanga Sibugay, unto this Honorable Court, most
respectfully offers the following exhibits formally:

EXHBITS PURPOSE/S

“A”/ “EE”and Formally offered to prove that a request

its sub-markings was made by the PDEA-ZSPDEO to the
(Written Request for ZamboangaSibugay Police Provincial
Laboratory Examination dated Crime Laboratory Office for the conduct
April 5, 2011) of laboratory examinations to determine
the presence of dangerous drugs on the
following items:
1. one (1) medium size heat- sealed
transparent plastic sachet containing
white crystalline substance
suspected to be “shabu” with
markings “PCL 04-05-11”, “MCL”
and “4/05/11; and,
2. one (1) medium size heat- sealed
transparent plastic sachet containing
white crystalline substance
suspected to be “shabu” with
markings “PCL-1 04-05-11”,
“MCL” and “4/05/11

“B” and Formally offered to prove that after the

its sub-markings accused were arrested, they were
(Written Request for Drug subjected to undergo drug testing in
compliance with Section 36(f) of R.A.

1
 Test dated April 5, 2011) No. 9165.
“C” and its sub- Formally offered to prove that after PSI
markings Mark Christian Maceda, PNP forensic
(Transparent Plastic Sachet) chemist, examined the two (2) heat-
sealed transparent plastic sachets
containing white crystalline substance
believed to be “shabu”, he placed the
same in a transparent plastic sachet
andthereafter made the corresponding
markings after sealing the same using a
masking type in order to preserve its
evidentiary value and integrity.
“D” and Formally offered to prove that when the
its sub-markings (2) heat- sealed transparent plastic sachets
(Orange Plastic Bag) containing white crystalline substance
believed to be “shabu” was the delivered
to the ZamboangaSibugay Police
Provincial Crime Laboratory Office and
received by PSI Mark Christian Maceda,
the same were placed in an orange plastic,
properly sealed and marked so that no
one can tamper the same and preserve in
the process its evidentiary value and
integrity.
“E” and Formally offered to prove that the same
its sub-markings was bought from the accused, by way of a
[one (1) medium size heat- buy- bust operation, and that the same
sealed transparent plastic had been tested positive of the presence
sachet containing white of methamphetamine hydrochloride,
crystalline substance commonly known as “shabu”, also
suspected to be “shabu” with offered to prove that the same was
markings “PCL 04-05-11”, properly marked and sealed.
“MCL” and “4/05/11]
“F” and Formally offered to prove that the same
its sub-markings was bought from the accused, by way of a
[one (1) medium size heat- buy- bust operation, and that the same
sealed transparent plastic had been tested positive of the presence
sachet containing white of methamphetamine hydrochloride,
crystalline substance commonly known as “shabu”, also
suspected to be “shabu” with offered to prove that the same was
markings “PCL-1 04-05-11”, properly marked and sealed.
“MCL” and “4/05/11]
“G” and Formally offered to prove that after two
its sub-markings (2) heat- sealed transparent plastic sachets
(Chemistry Report No. D-023- containing white crystalline substance
2011) believed to be “shabu” bought from the
accused were examined by the
ZamboangaSibugay Police Provincial
2

“H” and
its sub-markings
(Chemistry Report No. CDT-
022-2011, Chemistry Report
No. CDT-020-2011 and
Chemistry Report No. CDT-
021-2011)
“I” and
its sub-markings
(Written Request for
Registration of the Marked
Money, 500 peso bills, Rusty
Lopez paper bag and the
“budol” money )
“J” and
its sub-markings
(Buy- bust Money Receipt
dated April 5, 2011)
“K” and
its sub-markings
(Pre- Operation
Report/Coordination Sheet)
“L” and
its sub-markings
(Evidence Custody Record)
“M” and “N” together
with its respective
sub-markings
(Official Receipt and
Certificate of Registration of a
Hilux 4x4 pick- up Truck)
“O”, “P”, “Q” and “R”
together with its
respective
sub-markings
(Booking Sheet and Arrest
Crime Laboratory Office have been found
positive of the presence of
methamphetamine hydrochloride,
commonly known as “shabu”, and that
its aggregate weight is 98.423 grams.
Formally offered to prove that Section
36(f) of R.A. No. 9165 was properly
complied with.
Formally offered to prove that the marked
money used in the buy-bust operation was
duly registered before the Office of the
Provincial Prosecutor and that the
transaction was intended to be a sale and
for a consideration.
Formally offered to prove that the
registered marked money was duly
received by the poseur- buyer, IO1
PedritoSuano, Jr., before the buy- bust
operation.
Formally offered to prove that the buy-
bust operation was properly coordinated
with the PNP Ipil, ZamboangaSibugay.
Formally offered to prove that every
change of custody of the two (2) heat-
sealed transparent plastic sachets
containing white crystalline substance
believed to be “shabu”, which were
bought from the accusedwas properly
recorded.
Formally offered to prove that the
accused used a vehicle in the commission
of the crime.
Formally offered to prove that the arrests
of the accused were properly booked and
reported by the PDEA-ZSPDEO.
3
 Report of the Accused)
“S” and its sub-markings Formally offered to prove that arrests of
(Photographs of the accused) the accused were properly recorded.
“T and its sub- Formally offered to prove that items
markings” recovered/bought from the accused were
(Certificate of Inventory) properly inventoried and the inventory
was witnessed by those individuals
required under Section 21 of R.A. No.
9165.
“U and its sub- Formally offered to prove that at time of
markings” the inventory photographs were taken in
(Photographs) compliance with the requirement under
Section 21 of R.A. No. 9165.
“V and its sub- Formally offered to prove that PDEA-
markings” ZSPDEO, after the arrests of the accused,
(Certificate of Field Testing) conducted a field testing and found, based
on their appreciation, the two (2) heat-
sealed transparent plastic sachets
containing white crystalline substance
believed to be “shabu”, which were
bought from the accused have the
physical characteristics and texture of a
genuine “shabu”.
“W and its sub- Formally offered to corroborate the
markings” testimonies of IO1 Pedrito C. Suano and
(Certificate of Field Testing) IO1 Isidro S. Austria given before this
Honorable Court.
“AA and its sub- Formally offered to prove that the request
markings” of the PDEA-ZSPDEO for laboratory
(ZamboangaSibugay Police examinations were properly booked and
Provincial Crime Laboratory recorded.
Office Log Book)

If and when the foregoing exhibits are admitted in evidence, and

coupled with the oral testimonies of the prosecution witnesses, the State is
respectfully resting its case.

Ipil, ZamboangaSibugay, Philippines, May 27, 2012.

ORWIN LLOYD MONTAJES FAMOR

Associate Prosecution Attorney II
IBP Roll of Attorneys No. 56401
IBP No. 749700 (12.28.11/Ipil, ZSP)
MCLE Compliance No. III-0019580/01-24-11

Copy furnished:
 Atty. Pablo S. Ebol
4
Counsel for the Accused
Ipil, Zamboanga Sibugay