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REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION


REGIONAL TRIAL COURT
PROVINCE OF ILOCOS NORTE
CITY OF BATAC
BRANCH XVIII

THE PEOPLE OF THE PHILIPPINES,


Complainant,

CRIM CASE NO. 0327-92


- versus - FOR: RAPE WITH HOMICIDE

JOEL YATAR y QUIAOIT,


Accused.
x-----------------------------------------------x

FORMAL OFFER OF DOCUMENTARY EVIDENCE

ACCUSED by the undersigned counsel and unto this


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

EXHIBITS DESCRIPTION PURPOSE/S


1 Counter-Affidavit of To prove that the
the accused Joel accused did not
Yatar y Quiaoit commit the crime
charged against him

To prove that the


complainant
harbored ill-feelings
towards the accused

2 Sworn Affidavit of To prove that the


Juana Yatar accused did not
commit the crime
charged

To prove that the


accused was at her
house at around
12:30PM onwards

3 Sworn Affidavit of To prove that she


Martha Cruz personally know the
accused and the
victim

To prove that the


accused and victim
have always had a
good relationship
with each other
similar to that of a
father-daughter
relationship since
2009 up to the
present
4 Sworn Affidavit of the To prove on the fact
DNA Expert Dr. Gab and occurrence of
Gonzales secondary DNA
transfer

Aforesaid exhibits are being offered to prove that the crime and
accusation against the accused was NOT TRUE and was merely a
result of the ill-feelings of the accused towards the complainant.

WHEREFORE, premises considered, it is most respectfully


prayed to this Honorable Court that the foregoing documentary
exhibits be admitted for all purposes for which each and all said
exhibits were being offered in proving that the accused did not
commit the crime charged, and with the formal submission of the
aforesaid exhibits coupled with the testimonies of the witnesses
who testified thereon.

City of Batac, Ilocos Norte. April 24, 2017.

DE LARA & ALVIARNE LAW OFFICE


Counsel for the Accused
2nd floor, ABC Building
Ablan, Batac City, Ilocos Norte
By:

Atty. CLAUDETTE ABIGAIL B. DE LARA Atty. APRILLE S. ALVIARNE


ROLL No. 24680, 15 May 2012 ROLL No. 56789, 15 May 2012
IBP No. 09903456/1.05.2012 IBP No. 12098/ 1-20-2012
PTR No. 2468123/1.06.2017 I.N. PTR No. 7898505 1-3-2017 I.N.
MCLE Compliance No. V-0003456 MCLE Compliance No.
3.26.2015 X-00967, 1-6-2017
Batac City, Ilocos Norte (077)654-3425 Batac City, Ilocos Norte (077)654-3425

NOTICE OF HEARING

THE BRANCH CLERK OF COURT


Regional Trial Court, Branch 18
Batac City

Greetings!

Please submit the foregoing Formal Offer for the consideration


and approval of the Honorable Court immediately upon receipt
hereof.

Atty. Claudette Abigail de Lara


Counsel for the Accused

Atty. Aprille S. Alviarne


Counsel for the Accused
Copy furnished by personal service:

ATTY. MARVIN A. DIEGO


City Prosecutor
Office of the City Prosecutor, Batac City

ATTY. JOESHUA AGCAOILI


Private Prosecutor
Taft St., Batac City, Ilocos Norte

EXPLAINATION

Copies of the foregoing Formal Offer are served upon the


prosecution and filed with the Court by personal service.

Atty. Claudette Abigail de Lara


Counsel for the Accused

Atty. Aprille S. Alviarne


Counsel for the Accused