Offer for Stipulation

Admitted by the Defense:

1. Identity of the accused.

-Qualification: May be admitted only as to the identity of the accused as
stipulated in the information.
2. Jurisdiction of the court.
3. That a buybust operation was conducted.
-Qualification: There was a buybust but it was not a legitimate operation.
4. Place where the buybust was conducted.
-Qualification: It was not a legitimate operation.

Not Admitted by the Defense:

1. Selling of any Methamphetamine hydrochloride.

2. Possession of any Met HCl when the “buybust” was conducted.
3. Genuineness and due execution of the chemistry report.
4. Genuineness and due execution of the Possession item examination result.
5. Genuineness and due execution of the Buybust item examination result.
6. Genuineness and due execution of the urine sample result.
* Remember: NO COMPOUND STIPULATION!

ARRAIGNMENT

FILE A PETITION FOR BAIL. (after arraignment; take note: Sec. 11- non-bailable)
- Prosecution may oppose the Petition and present evidence to support the
opposition.

MARKING OF DOCUMENTS: (as presented by the Prosecution)

1. Exhibit A- Request for laboratory examination of Buybust item.

2. Exhibit B- Request for laboratory examination of Possession item.
3. Exhibit C- Request for chemical examination of urine sample.
4. Exhibit D- Result of Buybust item
5. Exhibit E- Result of Possession item.
6. Exhibit F- Result of urine sample.
7. Exhibit G- Markmoney photo.
8. Exhibit H- Affidavit of Poseur Buyer.
9. Exhibit I- Affidavit of Arresting officer.
10. Exhibit J- Shabu/Met HCl.
11. Exhibit K- Certification from PDEA.
12. Exhibit L- Blotter filed before the desk officer. *RESERVED to be marked.
13. Exhibit M- Inventory of Drug and Property seized.
14. Exhibit N- Pictures taken during the police operation.
MARKING OF DOCUMENTS: (as presented by the Defense)

1. Counter-affidavit.
2. Documents violating Sec. 21 of RA 9165. (Inventory must be immediately done at
the police station.)
3. Inventory report by the representative from DOJ. (Must be signed by the accused,
DOJ representative, barangay official and the media.
4. Pictures taken during the alleged buybust operations were lacking.

WITNESSES TO BE PRESENTED FOR BAIL HEARING:

*Forensic Analyst

PETITION FOR BAIL: (must e done 3 days before trial.)

CROSS-EXAMINATION of the Forensic Chemist.

*Defense: That the witness presented is not an expert analyst.