REPUBLIC OF THE PHILIPPINES Formatted: Font color: Text 1

Fourth National Capital Judicial Region Formatted: Not Highlight

Regional Trial Court Formatted: Font color: Text 1

Makati Branch 23, Trece Martires City Formatted: Not Highlight

Formatted: Font color: Text 1

PEOPLE OF THE PHILIPPINES Formatted: Not Highlight

Plaintiff, Formatted: Not Highlight

Formatted: Not Highlight

CRIMINAL CASE NO. Formatted: Left

R-MKT -16-02677- CP Formatted Table

-versus- (NPS No. XV-05-INQ-Formatted: Not Highlight

16K-0732 Formatted: Right

For: Violation of RA 9165 Formatted: Not Highlight

FRANCISCO CAMPOS Y REYES Sec 5 Formatted: Not Highlight

@Kiko AND MARLON Formatted: Not Highlight

TOLENTINO Y TOLENTINO Formatted: Not Highlight

@Marlon, Formatted: Centered

Accused. Formatted: Not Highlight
Formatted: Not Highlight

MA. KATHREEN HANNA P. DE GUZMAN Formatted: Not Highlight

Petitioner, Formatted: Font: Italic, Not Highlight
Formatted: Not Highlight

-versus- TPO-001-18 Formatted: Not Highlight

For: Application for Formatted: Right

Protection Order Formatted: Font: Italic, Not Highlight

under R.A. 9262 Formatted: Not Highlight

(Anti-Violence Formatted: Not Highlight

against Women and Formatted: Font color: Text 1

their Children)

ALVIN JAPHETH V. ALMARIO

Respondent
x - - - - - - - - - - - - - - - - - - - - - - - - - - - - --------x Formatted: Not Highlight
Formatted: Font color: Text 1

FORMAL OFFER OF EVIDENCE Formatted: Font color: Text 1

PetitionerPlaintiff, through the undersigned by counsel, and Formatted: Font color: Text 1

unto this Honorable Court, most respectfully offers in evidence the

following documentary exhibits: for the above-entitled case:

EXHIBIT DESCRIPTION PURPOSE

Exhibit Sachet of shabu (0.3 grams), To prove that:

A marked as “KIKO”
 Exhibit A is the exact same
sachet of shabu purchased from
Kiko.

Exhibit B Sachet of shabu (0.2 grams), To prove that:

marked as “KIKO-1”
Exhibit B is the exact same
sachet of shabu that was
confiscated from Kiko.

Exhibit 500-peso bill with serial To prove that:

C number UA818784, labeled
Exhibit “AOA” Exhibit C is the marked money
C-1 recovered from Kiko.

Exhibit Final Investigation Report To prove that:

D page 1
Exhibit Final Investigation Report Exhibit D, D-1 and D-1-A is the
D-1 page 2 Final Investigation Report
Exhibit Signature of PO3 Michael prepared and signed by PO3
D-1-A Danao Michael Danao detailing the
full conduct of investigation of
the buy-bust operation.

Exhibit F Photocopy of Buy Bust

Money

Exhibit Coordination Form Control To prove that:

G Number 10001-112016-0114
Signature of PSINSP Allan Exhibit G and G-1 is the formal
Exhibit Esquillo document evidencing the
G-1 coordination with PDEA for the
verification of the reports.

Exhibit Inventory/Acknowledgment To prove that: Formatted: Font color: Auto

H Receipt
Exhibit Signature of PO1 Andrew That the proper procedure in
H-1 Amante the
Exhibit Signature of PO1 Roderick inventory/acknowledgment
H-2 Perez and signing of confiscated
Exhibit Signature of Kapitan Tess illegal drugs has been complied
H-3 Brillante with in accordance with the
Chain of Custody rule.

Exhibit I PDEA Spot Report

Exhibit J Request for Laboratory To prove that:
Exhibit J- Examination
1 Signature of PO3 Michael That proper compliance with
Danao mandatory physical and mental
examinations was complied
with.

Exhibit Chemistry Report Number D To prove that:

K 2089-16
Exhibit Signature of PCINSP Ofelia That exhibit K and K-1 is the
K-1 Lirio Valleja exact chemistry report
prepared and signed by
PCINSP Ofelia Lirio Valleja.

Exhibit L Request for Drug Test To prove that:

Exhibit Signature of PO3 Michael
L-1 Danao That exhibit L is the requested
drug test by PO3 Michael
Danao to establish that

Exhibit Chain of Custody Form To prove that:

M Signature of PO1 Andrew
Exhibit Amante That the proper procedure from
M-1 Signature of PCINSP Ofelia seizure, marking and testing
Exhibit Lirio Valleja provided for under the chain of
M-2 custody rule has been complied
with.

That the sanctity and integrity

of the sachet of shabu marked
as “KIKO” and “KIKO-1”
including its contents has not
been diminished.

Exhibit Temporary Medical To establish that:

N Certificate of Marlon
Exhibit Tolentino Marlon Tolentino has
N-2 Signature of Dr. Irene undergone proper physical and
Columbano mental checkup conducted by
Dr. Irene Columbano.

Exhibit Temporary Medical To establish that:

O Certificate of Francisco
Exhibit Campos Francisco Campos has
O-1 Signature of Dr. Irene undergone proper physical and
Columbano
 mental checkup conducted by
Dr. Irene Columbano.

Exhibit P Joint Affidavit of Arrest page To prove that:

Exhibit 1
P-1 Joint Affidavit of Arrest page That exhibit P, P-1,P-2,P-2-A is
Exhibit 2 the Joint Affidavit of Arrest
P-2 Joint Affidavit of Arrest page signed by Andrew Amante and
Exhibit 3 Roderick Perez.
P-2-A Signature of PO1 Andrew
Exhibit Amante
P-2-A Signature of PO1 Roderick
Perez

Exhibit Affidavit of Undertaking That prove that:

Q Signature of Allan Esquillo
Exhibit The affidavit of undertaking
Q-1 contains the pertinent
information and data to
establish the proper compliance
with procedure.

Exhibit R Picture of the Location 1 To establish the precise location

Exhibit (taken during surveillance?) where the buy-bust operation
R-1 Picture of the Location 2 took place.
Exhibit Picture of the Location 3
R-2
Formatted: Font color: Text 1

EXHIBITS DESCRIPTION PURPOSE

To prove that:
1. The dating
A, A-1, A-2 Formatted: Font color: Text 1
Pictures of relationship of
and
petitioner together petitioner and the
A-31 Formatted: Font color: Text 1
with respondent respondent.
Consisting
Japheth Almario 2. As part of the
of 4 pages
testimony of
petitioner
Pictures of
To prove that:
B, B-1,B-2 petitioner with Formatted: Font color: Text 1
1. Physical injuries were
Consisting bruises and various
inflicted upon the petitioner
of 3 pages injuries all over her
by respondent.
body Formatted: Font: Book Antiqua
Formatted: Font: Book Antiqua
1Exhibits A, B, C, D, E, are attached to the Judicial Affidavit of petitioner, Ma. Formatted: Font: Book Antiqua
Kathreen Hanna De Guzman, and are already part of the court records. Formatted: Font: Book Antiqua
 2. As part of the testimony of
petitioner

To prove that:
1. Respondent has
harassed and
physically harmed
petitioner, and
threatened to and kill
or harm not only the
petitioner but her
mother and
sisterfamily members,
as well.
2. Respondent has
threatened to upload
and has actually
Screenshots of
spread their sexc
C Facebook messages Formatted: Font color: Text 1
videos and photos
consisting of from certain Neph
through social media.
23 pages respondent to Reyes
3. Respondent has
sent to petitioner
admitted to uploading
their videos on public
places such as Lyceum
of the Philippines
University Manila
Facebook page.
4. Respondent’s acts of
going near her home
has caused petitioner
to be afraid for her
family’s and her
personal safety.
5. As part of testimony of
petitioner.
To prove that:
1. Respondent has not
stopped harassing and
Screenshots of threatening petitioner
D Formatted: Font color: Text 1
Instagram messages by sending messages
Consisting
from the respondent through social media.
of 15 pages
April 2018 2. Respondent continues
to threaten give
petitioner ultimatums
to with harm on her
 and and have her
family members.
killed
3. Respondent’s threats,
harassment, and other
forms of violence
persist to this day
causing petitioner
intense emotional
anguish, suffering,
and psychological
trauma.
4. As part of testimony of
petitioner.
To prove that:
1. Respondent has been
uploadeding their sex
videos and nude photos on
Instagram and Facebook.

2.2. R Respondent has Formatted: Left, Line spacing: single, Border: Top: (No
border), Bottom: (No border), Left: (No border), Right:
continued to threaten
PNP Incident (No border), Between : (No border)
petitioner and her family of
E Record From dated Formatted: Font color: Text 1
with the uploading of more
19 February 2018
videos and photos on porn
sites and petitioner’s school
Facebook page.
3. Petitioner has reported
these threats and acts of
respondent to the PNP.
4. As part of the testimony of
petitioner.
To prove that:
Screenshots of 1. The witness Jam
Facebook messages herself has been
F2 by respondent to the threatened and Formatted: Font color: Text 1

Consisting witnesspetitioner’s harassed many times Formatted: Font color: Text 1

of 5 pages sister,es Ma. Jamila by the respondent.

P. De Guzman 2. Respondent has
(“Jam”) admitted sharing the
sex videos to

22Exhibits F,G,H, and I are attached to the Judicial Affidavit of witness, Ma.
Jamila De Guzman and are already part of the court records.
 petitioner and
witness’ aunt.
3. Respondent published
the sex videos and
photos and showed it
to third persons
including the witness.
4. As part of testimony of
witness, Ma. Jamila P.
De GuzmanAs part of
testimony of witness,
Ma. Jamila P. De
GuzmanJam.
To prove that:
1. Respondent used an
anonymous account to
publish the sex videos
Screenshots of and photos and show
G Facebook messages it to third persons Formatted: Font color: Text 1

Consisting from a certain including the witness.

of 1 page Marcus Barzagasent 2. As part of testimony of
by respondent. witness, Ma. Jamila P.
De GuzmanAs part of
the testimony of
Jamwitness, Ma.
Jamila P. De Guzman.
To prove that:
1. Respondent publicly
posted the nude
photos of petitioner
without her
permission.
2. Respondent, by
Screenshots of the uploading it in the
H Lyceum of the Lyceum Facebook Formatted: Font color: Text 1

Consisting Philippines page, allowed it to be

of 3 pages University Manila viewed by third
Facebook page persons and the
public.
3. Respondent, by
tagging petitioner in
the said nude photos,
made petitioner
readily identifiable
and caused her
 tremendous
humiliation.;
4. As part of the
testimony of witness,
Ma. Jamila P. De
Guzmanpetitioner
[SHOULD THIS BE
JAM?]
To prove that:
1. Witness Jam herself
has been threatened
and harassed by the
respondent.
2. Respondent has Formatted: Left
Screenshot of a
I threatened to kill the Formatted: Font color: Text 1
Facebook message
Consisting witnessJam, petitioner
from a certain Baby
of 1 page and their family.
Mgm
3. As part of the
testimony of witness,
Ma. Jamila P. De
Guzmanpetitioner Formatted: Font color: Text 1, Highlight

[SHOULD THIS BE Formatted: Font color: Text 1

JAM?]
To prove that:
1. Respondent has
published their his sex
videos with petitioner
Screenshot of
on YouTtube, a public
J Facebook message Formatted: Font color: Text 1
platform.
Consisting 1 from a certain
2. As part of testimony of
page Marcus Brazaga sent
witness, Ma. Jamila P.
by respondent.
De GuzmanAs part of
testimony of
petitioner [SHOULD
THIS BE JAM?]
To prove that:
Petitioner was treated
for the psychological
K trauma she suffered Formatted: Font color: Text 1
Receipts from
Consisting from respondent’s
Serene Consultancy
of 4 pages continuous
harassment.
1. As part of petitioner’s
testimony.
 To prove that:
Petitioner was treated
for the psychological
L trauma she suffered Formatted: Font color: Text 1
Prescription from
Consisting from respondent’s
Dr. Ng Chong Guan
of 2 pages continuous
harassment. Formatted: Font: Book Antiqua, 14 pt, Font color: Text
1
1. As part of petitioner’s
Formatted: Font color: Text 1
testimony.
To prove that:
Respondent was still
sendingcontinued to
Screenshots of
M send messages to Formatted: Font color: Text 1
Instagram messages
Consisting petitioner even after
from user
of 2 pages the issuance of the
“hannaxdg_1”
temporary protection
dated 8 June 2018
order.
1. As part of petitioner’s Formatted: Font: Book Antiqua, 14 pt, Font color: Text
1
testimony.
To prove that:
Respondent continued
to send was still
Screenshots of sending messages to
N Formatted: Font color: Text 1
Instagram messages petitioner even after
Consisting
from user the issuance of the
of 6 pages
“hannaxdg_1” temporary protection
order.
1. As part of petitioner’s
testimony.
O and sub- To prove that: Formatted: Font color: Text 1
markings, Respondent was still
O-1, O-2, O- sending continued to
Screenshots of
3, O-4, O-5, send messages to
Instagram messages
O-6, O-7, O- petitioner even after
from respondent
8, O-9, O-10, the issuance of the
(using the name user
O-11, O-12, temporary protection
O-13, O-14 “michellequeeniee”)
order.
Consisting 1. As part of petitioner’s
of 15 pages testimony.
To prove that:
Screenshot of
Respondent was still
Instagram story
continued to posting
P posted respondent Formatted: Font color: Text 1
nude photos of
(using the name by
petitioner even after
user “highhannap”)
the issuance of the
 temporary protection
order.
1. As part of petitioner’s
testimony.
To prove that:
Respondent was still
Screenshot of posting continued to
Instagram story post nude photos of
posted by petitioner even after
Q Formatted: Font color: Text 1
respondent (using the issuance of the
the name user temporary protection
“highhannap”) order.
1. As part of petitioner’s
testimony.
To prove that:
1. Respondent
continueds to send
Screenshot of messages to petitioner
Instagram story and to threaten her
posted by even after the issuance
R Formatted: Font color: Text 1
respondent (using of temporary
the name user protection order.
“michellequeeniee”) 2. As part of petitioner’s
testimony.Respondent
is still sending threats
to petitioner
To prove that:
Respondent was still
Screenshot of continued to posting
Instagram story nude photos of
posted by petitioner even after
S Formatted: Font color: Text 1
respondent (using the issuance of the
the name user temporary protection
“highhannap”) order.
1. As part of petitioner’s
testimony.
To prove that:
Screenshot of 1. Respondent
Instagram story continueds to send
posted by messages to petitioner
T Formatted: Font color: Text 1
respondent (using and to threaten her
the name user even after the issuance
“highhannap”) of temporary
protection order .
 2. As part of petitioner’s
testimony.Respondent
is still sending threats
to petitioner
To prove that:
1. Respondent has set up
Screenshot of Formatted: Left
a public profile to post
Instagram story
petitioner’s nude
posted by
photos and videos.
U respondent (using Formatted: Font color: Text 1
Respondent continues
the name
to harass petitioner.
“highhannap”)user
2. As part of petitioner’s
“highhannap”
testimony.

To prove that:
1. Same purposes as
Exhibits P to
Compact disc U.Respondent was
containing the still posting nude
photos and videos photos and videos of
V Formatted: Font color: Text 1
(Exhibits P to U) that petitioner evn after the
rRespondent has issuance of the
posted on Instagram temporary protection
order
2. Respondent continues
to harass petitioner
: Formatted: Font color: Text 1

PRAYER Formatted: Font: Bold, Font color: Text 1

Aforesaid exhibits are being offered to prove that the allegations of Formatted: Centered

the petitioner against the respondent are true and have basis under Formatted: Font color: Text 1

the law.

WHEREFORE, premises considered, it is most respectfully

prayed upon this Honorable Court that the foregoing documentary
exhibits be admitted for the purposes for which they were offered,
in support of the application for a PPO and petitioner’s Motion for
Sanctions and its Supplement.each and all of the said exhibits were
offered.

Other reliefs just and equitable under the premises are

likewise prayed for.

Makati City for Trece Martires, CaviteMakati City City,. 3 Formatted: Font color: Text 1

August 3, 201814 May 2019. Formatted: Font color: Text 1

 ATENEO LEGAL SERVICES CENTER
Counsel for the AccusedPetitioner
Room 108, Ground Floor
Ateneo Professional Schools Building
Rockwell Center, Makati City 1200
Tel. No.: (632) 8997691 loc. 211
Fax No.: (632) 8994342
Email: alsc.law@ateneo.eduOFFICE OF THE
PUBLIC PROSECUTOR
By:
RUPERT AXEL M. CRUZTRISTAN HAO
Roll of Atty. No. 4840411111
IBP Lifetime No. 0507033333; 1/10/201005;
MakatiRSM
PTR No. MKT6614818MKT6666666; 1/4/20198;
Makati City
MCLE Compliance No. V–00183180088888;
4/8/20196
Mobile No. +63 918 9072336________
Email: amcruz@ateneo.edu___________
And by:
MARIA PATRICIA R. CERVANTES-
POCOJEMELLE LOUISE ANNE
TAMBAOAN
Roll of Attorneys No. 5865022222
IBP Lifetime Member No. 55555; Makati
PTR No. MKT6614918MKT7777777; 1/4/20198;
Makati City
IBP Lifetime Member No. 09043; Makati City
MCLE Compliance No. V-00157540099999;
4/8/2019 2/29/16
Mobile No. +63 917 52089795634320
Email:
mpcervantes@ateneo.edujeltambaoan@gmail.c
om
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COPY FURNISHED:

ATTY. CARLO EDISON ALBA ANGELO HERBOSA

Public Attorney’s Office
Government Center Building
Trece Martires, CavitMakati City Hall, Makati Citye Formatted: Highlight

[PUT PAO AND HIS OFFICE ADDRESS]
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With my conformity:

MA. KATHREEN HANNA P. DE GUZMAN

Petitioner