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 -

VIOL. OF SEC. 5, RA 9165

TONG AFDAL NANDANG

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

A/ EEand
its sub-markings
(Written Request for
Laboratory Examination
dated
April 5, 2011)

B and
its sub-markings
(Written Request for Drug

PURPOSE/S
Formally offered to prove that a request
was made by the PDEA-ZSPDEO to the
ZamboangaSibugay Police Provincial
Crime Laboratory Office for the conduct
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
Formally offered to prove that after the
accused were arrested, they were
subjected to undergo drug testing in
compliance with Section 36(f) of R.A.
1

Test dated April 5, 2011)

C and its submarkings

(Transparent Plastic Sachet)

D and
its sub-markings
(Orange Plastic Bag)

E and
its sub-markings
[one (1) medium size heatsealed transparent plastic
sachet containing white
crystalline substance
suspected to be shabu with
markings PCL 04-05-11,
MCL and 4/05/11]

F and
its sub-markings
[one (1) medium size heatsealed transparent plastic
sachet containing white
crystalline substance
suspected to be shabu with
markings PCL-1 04-05-11,
MCL and 4/05/11]

No. 9165.
Formally offered to prove that after PSI
Mark Christian Maceda, PNP forensic
chemist, examined the two (2) heatsealed 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.
Formally offered to prove that when the
(2) heat- sealed transparent plastic sachets
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.
Formally offered to prove that the same
was bought from the accused, by way of a
buy- bust operation, and that the same
had been tested positive of the presence
of methamphetamine hydrochloride,
commonly known as shabu, also
offered to prove that the same was
properly marked and sealed.
Formally offered to prove that the same
was bought from the accused, by way of a
buy- bust operation, and that the same
had been tested positive of the presence
of methamphetamine hydrochloride,
commonly known as shabu, also
offered to prove that the same was
properly marked and sealed.

Formally offered to prove that after two

(2) heat- sealed transparent plastic sachets
its sub-markings
(Chemistry Report No. D-023- containing white crystalline substance
believed to be shabu bought from the
2011)
accused were examined by the
ZamboangaSibugay Police Provincial

G and

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.

H and
its sub-markings
(Chemistry Report No. CDT022-2011, Chemistry Report
No. CDT-020-2011 and
Chemistry Report No. CDT021-2011)

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

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 buybust operation was properly coordinated
with the PNP Ipil, ZamboangaSibugay.
Formally offered to prove that every
change of custody of the two (2) heatsealed 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.

(Official Receipt and

Certificate of Registration of a
Hilux 4x4 pick- up Truck)

O, P, Q and R
together with its
respective
sub-markings

Formally offered to prove that the arrests

of the accused were properly booked and
reported by the PDEA-ZSPDEO.

(Booking Sheet and Arrest

3

Report of the Accused)

S and its sub-markings Formally offered to prove that arrests of

(Photographs of the accused)

T and its submarkings

(Certificate of Inventory)

U and its submarkings

(Photographs)

V and its submarkings

(Certificate of Field Testing)

W and its submarkings

(Certificate of Field Testing)

AA and its submarkings

(ZamboangaSibugay Police
Provincial Crime Laboratory
Office Log Book)

the accused were properly recorded.

Formally offered to prove that items
recovered/bought from the accused were
properly inventoried and the inventory
was witnessed by those individuals
required under Section 21 of R.A. No.
9165.
Formally offered to prove that at time of
the inventory photographs were taken in
compliance with the requirement under
Section 21 of R.A. No. 9165.
Formally offered to prove that PDEAZSPDEO, after the arrests of the accused,
conducted a field testing and found, based
on their appreciation, the two (2) heatsealed 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.
Formally offered to corroborate the
testimonies of IO1 Pedrito C. Suano and
IO1 Isidro S. Austria given before this
Honorable Court.
Formally offered to prove that the request
of the PDEA-ZSPDEO for laboratory
examinations were properly booked and
recorded.

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:
4

Atty. Pablo S. Ebol

Counsel for the Accused
Ipil, Zamboanga Sibugay