REPUBLIC OF THE PHILIPPINES

Municipal Trial Court of Bula

Fifth Judicial Region
Bula, Camarines Sur
NELIA D. BERINGUELA,
Protestant,
-vs-

EP CASE NO. 03

NONITO B. ESTEVE,
Protestee.
x------------------------------x

COMMENT TO THE MOTION FOR TECHNICAL

EXAMINATION OF BALLOTS

Protestant, through counsel, unto this Honorable Court respectfully submit a

comment to the Motion for Technical Examination of Ballots as follows:
1. The Motion for technical examination of ballots was received on December
3, 2013 by registered mail;
2. The court can make a determination without the need of calling handwriting
experts nor an evidence aliunde is necessary to enable this Honorable Court
to determine the genuineness of the handwriting on the ballots, in fact, an
examination of the ballot itself is sufficient;
3. Be it noted that there was likewise no issue alleged by the protestee
involving irregularities or anomalies in the conduct of the election on
October 28, 2013 but rather for misappreciation of ballots.

PRAYER

WHEREFORE, on the basis of the foregoing premises, the motion for

technical examination of ballots should be DENIED.
Protestant prays for other reliefs that are just and equitable under the premises.
NABUA, CAMARINES SUR, PHILIPPINES for BULA, CAMARINES SUR,
PHILIPPINES, December 6, 2013.
_____________________________
ATTY. ROMEO B. ABACA. JR.
Counsel for the Protestant
IBP Receipt No. 887032 12/06/2012
PTR No. 1396294-C 01/08/2013
MCLE CERTIFICATE OF COMPLIANCE NO. IV IN PROCESS
(Awaiting receipt of MCLE Certificate of Compliance No. IV from the
Supreme Court-MCLE Committee)
Roll of Attorneys No. 52436
Lazarte Bldg., San Francisco, Nabua, Camarines Sur
Cellular Phone Number 0917-513-3134
EXPLANATION
Service of the foregoing comment to motion for reconsideration of the
Honorable Court dated November 21, 2013 was done thru registered mail due to
distance and lack of office manpower to effect personal service.
_____________________________
ATTY. ROMEO B. ABACA. JR.
Copy furnished:
ATTY. IRENE C. CUNANAN-ESTRELLADO
Counsel for the protestee
Liberty Insurance Corporation
Door 3, Panganiban Drive, Naga City