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CASES CHUN & ASSOCIATES

LAW OFFICES
PAULINO E. CASES, JR. OUR REF : _________
IAN STEVEN C. CHUN
- YOUR REF: _________
PEDRO F. OFIANA, JR.
G. SILAS I. TADTAD, JR.
BUENAVISTA MAE BAUTISTA
MARIE ROSE M. ROSALES

July 4, 2018

HON. WINSTON MENDOZA


ASSITANT CITY PROSECUTOR
Office of the City Prosecutor
Antipolo City

Re: Criminal Case Nos. 12-44886 and 12-44887 entitled “People


of the Philippines vs. Jann Javellana y Perez” and “People of the
Philippines vs. Martin Javellana y Perez”

Dear Hon. Mendoza:

We write in behalf of our client, BANK OF THE


PHILIPPINE ISLANDS, regarding the original copies of Exhibits
“A,” “A-1,” “C,” “D,” and “E” which are currently in your custody,
subject matter of the above-entitled case now pending before the
Regional Trial Court, Branch 100 of Antipolo City.

On May 8, 2018, undersigned counsel as private prosecutor in


the above-entitled case has concluded the presentation of its evidence.

Thus, on the same date, or on May 8, 2018, the Honorable


Court directed the private prosecutor to submit its Formal Offer of
Evidence within a period of fifteen (15) days from said date, on until
May 23, 2018.

However, on May 23, 2018, private prosecutor filed a Motion


for Additional Time to File Formal Offer of Evidence requesting an
additional period of fifteen (15) days from May 23, 2018, or until June
7, 2018 to submit the Formal Offer of Evidence.

On, June 7, 2018, private prosecutor filed an Urgent Motion to


Defer Submission of Formal Offer of Evidence (with Motions to

Unit 408 Cityland Condominium 10 Tower II, 154 H. V. Dela Costa Street, Salcedo Village, Makati City, Metro Manila, Philippines
P. O. Box 2475, MCPO, 1276 Makati, Tel. Nos. 813-7576; 892-2338; 867-16-08; 812-4619 Telefax: (63) (2) 813-7028.
Recall Private Complainant’s Witness Mr. Limwell G. Macasaet and
for the Issuance of Subpoena Ad Testificandum) with the Court.

In view of the foregoing, we respectfully request that the


original copies of the following be turned over to the undersigned
counsel for its formal offer of evidence:

1. Exhibit “A” – Complaint Affidavit executed by Limwell


Macasaet;
2. Exhibit “A-1” – Joint Affidavit of Arrest executed by SPO1
Eduardo Manreza and SPO2 Sunny Boy Mendez;
3. Exhibit “C” – Complaint Sheet executed by Limwell G.
Macasaet;
4. Exhibit “D” – Booking Sheet and Information Report of
Martin Palaez Javellana and Jann Perez Javellana; and
5. Exhibit “E” – Special Power of Attorney executed by
Aniceta P. Delmundo.

In connection to this, Mr. Franklin F. Ramirez, one of the


liaison officers of the undersigned counsel and whose signature
appears below, is hereby authorized to receive the aforesaid originals
of the aforesaid documents.

We trust that you would give your utmost preferential attention


on the matter.

Thank you.

Very truly yours,

Buenavista Mae Bautista


For the firm
Copy furnished:
Honorable Regional Trial Court
Branch 100, Antipolo City

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