REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

Seventh Judicial Region
Branch 101
Cebu City

PEOPLE OF THE PHLIIPPINES,

Plaintiffs

CRIM CASE NO. CEB-C-1123

versus
For: LIBEL

RIZAL FAJARDO,
Accused.
x--------------------------------------x

FORMAL OFFER OF DOCUMENTARY EXHIBITS

Private Complainant, through counsel, respectfully files this FORMAL

OFFER OF EVIDENCE for marking and admission of the following:

EXHIBIT DOCUMENT PURPOSE

A The Universal Serial Bus
(USB) or Flash Drive
containing the recorded
video of the program
“Reklamo Publiko”
A-1 The Sworn Affidavit of Ms.
Annelia Villaflores Pepito of
SkyCable Corporation in
relation to the recorded
video
B Judicial Affidavit of Sulpicio To prove that the accused committed the
Gonzales Sr.
To prove the existence of that segment of
the radio program “Reklamo Publiko”
wherein the defamatory and malicious
statements against the private
complainant were uttered.
To prove that the same program “Reklamo
Publiko” was also aired and broadcasted
over the television and that the recorded
video is authentic and came from a
legitimate source whose nature of
business involves the recording of
programs in the ordinary course of
business.
crime of Libel by making defamatory
 remarks against the private complainant
over the radio through his malicious
imputations which included matters not
anymore related to the latter’s function as
a public official.
B-1 The signature of Sulpicio To prove the truthfulness and veracity of
Gonzales Sr. the judicial affidavit filed by the private
complainant as well as the fact that he
was the one who actually and voluntarily
executed the document based on his
personal knowledge.
C Judicial Affidavit of To prove the element of publicity when
Cassandra Mondragon the program was in fact broadcasted over
the radio and was made available to
public listeners as well as to prove the
malicious utterances made by the accused
during that program.
C-1 The signature of Cassandra To prove the truthfulness and veracity of
Mondragon the judicial affidavit filed by the witness as
well as the fact that she was the one who
actually and voluntarily executed the
documents based on her personal
knowledge.
D Endorsement Letter To prove that the utterances made by the
addressed to the Head of accused regarding the alleged balance of
Vicente Sotto Memorial twelve billion pesos (P12,000,000,000.00)
Medical Center from the rehabilitation fund, which were
allegedly used by the private complainant
for his own benefit, are malicious in that
all allotments under the private
complainant’s name were released
directly to Vicente Sotto Memorial
Medical Center and no government funds
whatsoever remained in the custody of
the private complainant.
E Certificate from DBM dated To prove that the utterances made by the
2010 accused regarding the alleged twenty
billion pesos (P20,000,000,000.00)
rehabilitation fund are malicious in that
only seventy-million (P70,000,000.00)
pesos were allotted to the private
complainant for the year 2010 with the
corresponding Notice of Cash Allocation
given to Vicente Sotto Memorial Medical
 Center.
F Certificate from DBM dated To prove that the utterances made by the
2013 accused regarding the alleged twenty
billion pesos (P20,000,000,000.00)
rehabilitation fund are malicious in that
no public funds were allotted to the
private complainant for the year 2013.
G Certificate from DBM dated To prove that the utterances made by the
2019 accused regarding the alleged twenty
billion pesos (P20,000,000,000.00)
rehabilitation fund are malicious in that
no public funds were allotted to the
private complainant for the years 2013 to
2019.
H Court Clearance issued by To prove that the words “kawatan”,
the Office of the Clerk of “mangamang”, and “mandurugas” uttered
Court of the Regional Trial by the accused have publicly and
Courts Cebu City maliciously imputed a crime against
private complainant because in truth and
in fact there were no existing cases filed
against the latter for Malversation,
Election Offenses, and R.A. 9165
violations, or for any other crimes.
I General Appropriations Act To prove that the utterances made by the
as of 2018 showing the accused regarding the alleged twenty
amount appropriated to the billion pesos (P20,000,000,000.00)
House of Congress, rehabilitation fund are malicious in that
particularly the House of such amount is even more than the total
Representatives amount actually appropriated to the
House of Representatives.

PRAYER

WHEREFORE, it is most respectfully prayed of this Honorable Court to admit

the foregoing documentary exhibits for the purposes they are each offered.

Cebu City, Philippines, September 14, 2019.

BABA MEPA JAGIDO LAW FIRM

Counsel for the Private Complainant
Fuente Rotonda, Cebu City
Telephone No. (032) 262-0081
Email Add: maryannelaw@gmail.com
 By:

ATTY. MARY ANNE B. JAMISOLA

Roll No. 88899
PTR No. 123456 Feb 14, 2019 Cebu City
IBP Lifetime No. 1234567 Cebu City Chapter
MCLE Compliance No. VII-01234232

Copy furnished:

The Honorable Public Prosecutor

Cebu City
By personal service: Received by: __________________________

VVE PLLaSa Law Office

Counsel for the Accused
305-A 3rd flr., Medalle Building,
Osmena Boulevard, Cebu City
By personal service: Received by: ___________________________