We join the manifestation of the defense counsel, Your Honor.

1. Will the accused admit the jurisdiction of the court?

2. Will the accused admit her identity?
STIPULATION OF FACTS:
1. Will the accused admit that the accused on the ____ day of _________, 20___ is at
_____________________________?
2. Will the accused admit that on the same date and time aforementioned, the accused
handed to ___________________, 2 sachets of white crystalline substance?
3. Will the accused admit that in exchange to the two sachets of crystalline substance, she
received from ______________________ three (3) hundred pesos bills?
4. Will the accused admit that he was arrested at __________________?
5. Will the accused admit that he executed an Affidavit of
___________________________?
PREMARKING OF DOCUMENT AND OBJECT EVIDENCE:
We are now ready to mark our evidence, Your Honor.
1. As Exhibit A, we present the Confiscation Receipt
- For the purpose of proving the compliance with Section 21 of RA 9165
2. As Exhibit B, we present the Request for laboratory examination
- For the purpose of proving the chain of custody of the object evidence and to prove that
what was seized from herein accused was promptly submitted for laboratory
examination
3. As Exhibit C, Chemistry Report 1 (Shabu)
- For the purpose of proving the subject evidence that were seized from the accused are
prohibited drugs
4. As Exhibit D, Request for laboratory examination of UV powder
- For the purpose of proving the marked money that was recovered was submitted for
ultraviolet examination
5. As Exhibit E, Chemistry Report 2 (UV Powder)
- For the purpose of proving herein accused received marked money from the poseur
buyer during the buy-bust operation

6. As Exhibit F, Two (2) sachets of Shabu

- For the purpose of proving the Corpus Delicti / existence of the prohibited drugs
7. As Exhibit G, Affidavit of the Poseur Buyer
- For the purpose of proving that the accused and the one who sold the prohibited drugs is
one and the same
8. As Exhibit H, Affidavit of Arrest
- For the purpose of proving that the accused was lawfully arrested while committing the
said prohibited act
9. As Exhibit I, Three (3) marked money 100 pesos bills
- For the purpose of proving the Corpus Delicti, / that the accused sold the two sachets of
crystalline substance to the poseur buyer

ISSUES
1. Whether or not the accused committed the crime charged.
2. Whether or not she is guilty thereof.
WITNESSES
1. PO2 Joanna Rizza B. Mandap of the Philippine Drug Enforcement Agency
- To testify that a buy-bust operation took place and that she was the one who acted as the
poseur buyer and was the one who gave the three (3) P100.00 bill marked money with Serial
Nos.______________________________
2. PO2 Elizabeth Joie Cruz of the Philippine Drug Enforcement Agency
- To testify that a buy-bust operation took place and that she was the one who went to the
scene of the crime and arrested the accused
3. SPO3 Reynaldo Prudenciado, Investigator, Philippine National Police
- To testify that he was the one who investigated the accused and the one who requested
for the examination of the marked money and the left hand of the accused
4. Judy Anne Y. Yulo, Forensic Chemist
- To testify that she conducted the laboratory examination o f t h e s e i z e d p r o h i b i t e d
drugs and the marked bills and to attest to the veracity of her findings in
t h e chemistry report

-To t e s t i f y t h a t s h e c o n d u c t e d t h e l a b o r a t o r y e x a m i n a t i o n o f
the seized prohibited drugs and to attest to the veracity of her findings in
t h e chemistry report
5. Maureen Kay Patajo, mediaman from ABS CBN
-To testify the inventory of the confiscated items
We move for the termination of the Pre Trial, Your Honor