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Comment On Formal Offer of Exhibit Niel Arevalo

This document contains the defense counsel's objections and comments regarding exhibits offered by the prosecution in Criminal Case No. 14-4976-C, where Niel Arevalo y Dequina is accused of violating R.A. 10591. The defense admits the existence of exhibits A through I but denies or questions the contents, markings, and evidentiary weight of several of the exhibits. The defense requests that the court consider its objections and comments on the exhibits offered by the prosecution.

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Ralph Romeo Bascones
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215 views4 pages

Comment On Formal Offer of Exhibit Niel Arevalo

This document contains the defense counsel's objections and comments regarding exhibits offered by the prosecution in Criminal Case No. 14-4976-C, where Niel Arevalo y Dequina is accused of violating R.A. 10591. The defense admits the existence of exhibits A through I but denies or questions the contents, markings, and evidentiary weight of several of the exhibits. The defense requests that the court consider its objections and comments on the exhibits offered by the prosecution.

Uploaded by

Ralph Romeo Bascones
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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Republic of the Philippines

REGIONAL TRIAL COURT


6th Judicial Region
Branch 60, Cadiz City

PEOPLE OF THE PHILIPPINES, CRIM. CASE NO. 14-


Complainant, 4976-C
-versus-

NIEL AREVALO y DEQUINA for: Violation of R.A. 10591


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

COMMENTS/OBJECTIONS TO EXHIBITS FORMALLY


OFFERED BY THE PROSECUTION FOR ADMISSION

DEFENSE, by undersigned counsel, unto the Honorable Court most


respectfully states its objections to and/or comments on the exhibits formally
offered by the prosecution for admission, as follows:

EXHIBIT NATURE and COMMENT

“A” Joint Affidavit of Arrest of PO3 Jorge Napilan and


PO2 Warren Lex Dela Cruz

Comment/Objection: Defense admits the existence of Exhibit A and its


sub-markings. However, Defense denies the contents of the same as self-
serving.

“B” Affidavit of Jose M. Alde, Jr.

Comment/Objection: Defense admits the existence of Exhibit B and its


sub-markings. However, defense has no admission as to the contents of the
said exhibit and sub-markings. The same is self-serving.

“C” Remittance Encashment Manifesto

Comment/Objection: Defense admits the existence of Exhibit C and its


sub-markings. However, defense has no admission as to the contents of the
said exhibit and sub-markings.
“D” Affidavit of Henry Melocoton

Comment/Objection: Defense admits the existence of Exhibit D and its sub-


markings. Defense objects the transferring of the marking from the
photocopy to the original. What was presented in court was only the
photocopy.

“E” Police Blotter Entry with entry no. 20140489

Comment/Objection: Defense admits the existence of Exhibit E and its sub-


markings. The same piece of evidence is self-serving.

“F” Photograph of the firearm, holster and 6 ammunition

Comment/Objection: Defense admits the existence of Exhibit F and its sub-


markings. However, defense has no admission as to the contents of the said
exhibit and sub-markings.

“G” Certification from Firearm and Explosives Office


dated January 10, 2018

Comment/Objection: Defense admits the existence of Exhibit G and its


sub-markings. However, defense has no admission as to the contents of the
said exhibit and sub-markings.

“H” .357 caliber revolver magnum

Comment/Objection: Defense admits the existence of Exhibit H and its


sub-markings. However, defense has no admission as to the identity of the
same object as it has no serial number or distinct mark that would make the
same a specific object used in the crime. The marking JMN which is
presented as Exhibit “H-1” is questionable as the marking was made after
the alleged arrest.

“I” Six Live Ammunition “RCD” marking

Comment/Objection: Defense admits the existence of Exhibit I and its


submarkings but stresses that the same has no evidentiary weight as they are
but a product of questionable and illegal seizure which is a product of the
illegal arrest of the accused.
PRAYER

WHEREFORE, it is most respectfully prayed of the Honorable Court that the


foregoing comments and/or objections be considered.

Other just and equitable relief under the circumstances are also prayed for.

RESPECTFULLY SUBMITTED. Cadiz City, Philippines.

26 April 2019.

PUBLIC ATTORNEY’S OFFICE


Counsel for the Accused
Cadiz City District Office
Counsel for the Movant
2/F SGE Building
Cabahug Street, Cadiz City

By:

RALPH ROMEO B. BASCONES


Public Attorney I
Roll No. 70712
IBP No. 062827/01-04-19/Pasig City
MCLE Compliance - Admitted to the Bar 2018

HON. JANE DEE V. MADERAZO


OIC-City Prosecutor
Cadiz City

Madame:
Please submit to the Honorable Court immediately upon receipt hereof for its
kind consideration and resolution the foregoing Comments/Objections to the
exhibits formally offered by the prosecution for admission.

Thank you.

RALPH ROMEO B. BASCONES


ATTY. FELIX G. GUARNES, JR.
Clerk of Court VI
RTC, Branch 60
Cadiz City

Sir:

Please submit to the Honorable Court immediately upon receipt hereof for its
kind consideration and resolution the foregoing Comments/Objections to the
exhibits formally offered by the prosecution for admission.

Thank you.

RALPH ROMEO B. BASCONES

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