Republic of the Philippines

REGIONAL TRIAL COURT

7th Judicial Region
Cebu City, Branch 101

PEOPLE OF THE PHILIPPINES,

Plaintiff,
Criminal Case No. CEB-C-1145
For: Murder
-versus-

BILL W. KADAGAN,
Accused.
x - - - - - - - - - - - - - - - - - - - - - - - -x

FORMAL OFFER OF DOCUMENTARY AND OBJECT EVIDENCE

PLAINTIFF by the undersigned counsel and unto this Honorable Court,

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

EXHIBIT DOCUMENT/OBJECT PURPOSE

“A” Knife To establish the fact that the

said kitchen knife was the
weapon used to murder
Carla Saclolo and that it
belongs to the accused Bill
Kadagan.
“B” T-shirt of Carla Saclolo To establish the fact that the
said T-shirt belonged to
Carla Saclolo, the victim.
“C” Entry on Police Blotter by To establish the fact that
Senior Police Officer II Carlos Saclolo appeared at
Romeo Aying conducted on CCPO Station 3 and
December 7, 2018 reported that the accused,
Bill Kadagan, made some
violent threats to him and
his wife (the victim). This
is to further establish that
fact that the threats were
made by the accused

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 against both of them prior
to the stabbing incident.
“D” Stained T-shirt of Bill To establish the fact that the
Kadagan said T-shirt which is stained
with the victim’s blood,
was worn by the accused
during the stabbing incident
and that it belongs to the
accused, Bill Kadagan
“E” Spot Report To establish the fact that the
crime was timely reported
to the police and timely
acted upon by them. This is
to further establish the
place and time of the arrest
of the accused as well as
the record of the items
recovered in his possession
during his arrest.
“F” Entry on Police Blotter by To establish the fact that
Senior Police Officer II Carlos Saclolo appeared at
Raul Reyes on December CCPO Station 2 and
25, 2018 reported the stabbing
incident which resulted to
his wife’s demise. This is
to further establish the fact
that the complainant
witnessed the incident and
had a personal encounter
with the accused whom he
identified to be Bill
Kadagan
“G” Crim Lab Autopsy on Carla To establish the fact that
Saclolo conducted by Dr. Carla Saclolo, upon
Ana Chua examination of her body by
Dr. Ana Chua, died from
severe internal injuries due
to multiple stab wounds,
head, chest and back region
“H” Judicial Affidavit of To establish the fact that
Shauntelle De Guzman accused committed the
crime of Murder
“I” Judicial Affidavit of Jayden To establish the fact that
De Guzman accused committed the
crime of Murder

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“I-1” Signature of Jayden De To establish the fact that it
Guzman in his Judicial is Jayden De Guzman who
Affidavit executed the affidavit as
evidenced by his signature
which is affixed therein.
“J” Judicial Affidavit of Pearl To establish the fact that the
Madrigal accused, Bill Kadagan, was
arrested by the Police in his
apartment which was
owned by the witness, Peal
Madrigal.
“K” Judicial Affidavit of Romeo To establish the fact that the
Aying accused went to the
residence of the
complainant and his wife
(the victim) prior to the
stabbing incident and made
a commotion in their
neighborhood. This is to
further establish the fact
that the accused made
threats against both of
them.
“L” Black Cap of Bill Kadagan To establish the fact that the
cap was the same cap worn
by the accused during the
stabbing incident and that it
belongs to the accused, Bill
Kadagan.
“M” Judicial Affidavit of Carlos To establish the fact that the
Saclolo complainant has personal
knowledge of the facts
surrounding the case. This
is to further certify that he
witnessed the stabbing
incident which resulted to
his wife’s demise and had a
personal encounter with the
accused whom he identified
to be Bill Kadagan.
“M-1” Signature of Carlos Saclolo To establish the fact that it
in his Judicial Affidavit is Carlos Saclolo who
executed the affidavit as
evidenced by his signature
which is affixed in the
complaint-affidavit.

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 PRAYER
WHEREFORE, it is most respectfully prayed of this Honorable Court to
admit the forgoing documentary exhibits for the purposes they are each offered.

Cebu City, Philippines. September 12, 2019

ATTY. JUNE PAOLO C. SAGURAN

Counsel for the Plaintiff
Roll of Attorney's No. 876543
PTR NO. 12345, Cebu City, 11/2/19
IBP Lifetime No. 234567, 5/28/12
Roll of Attorney's No. 987653
MCLE Compliance No.567890
Saguran, Castillo and Associates
14th Floor GV Tower, Sanciangko Street,
Cebu City

By: ATTY. HAREL MARI M. CASTILLO

Roll of Attorney's No. 539201
PTR NO. 009E82, Cebu City, 12/2/19
IBP Lifetime No. 163917, 6/28/11
Roll of Attorney's No. 539201
MCLE Compliance No. 3801073
Saguran, Castillo and Associates
14th Floor GV Tower, Sanciangko Street,
Cebu City

Copy Furnished:

The Honorable Public Prosecutor

Cebu City, Philippines
By personal service. Received by: _____________________

Atty. Romielyn Macalinao

Counsel for the Accused
Ramas and Associates Law Firm
Cebu City, Philippines
By personal service. Received by: _____________________