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Republic of the Philippines

REGIONAL TRIAL COURT


11th Judicial Region
Branch 21
Bansalan, Davao del Sur

PEOPLE OF THE PHILIPPINES, CRIM. CASE NO. XXI-1495


(10)
Plaintiff,
- versus MICHAELO FLORENTINO,
LYNDON MONDAY, AND
RAMON RODRIGUEZ
Accused.

FOR: ROBBERY WITH RAPE

x============================================================/

COMMENT OR OPPOSITION TO THE FORMAL OFFER OF


EXHIBITS
Comes now the STATE, through the undersigned counsel and unto
this Honorable Court, most respectfully submits this Comment or
Opposition to the Formal Offer of Exhibits filed by the defense and avers:
1

That the undersigned counsel received an Order from this


Honorable Court directing the undersigned counsel to file his
comment to the Defenses Formal Offer of Exhibits;

That in relation thereto, PLAINTIFF through the undersigned


counsel forwards the following comments or oppositions:

Exh. 1 : COUNTER-AFFIDAVIT OF MICHAELO FLORENTINO is


admitted as to its existence but is objected as to the purpose to
which it is being offered.
1 As can be gleaned in the affidavit, the statements and claims of
the accused, Mr. Florentino, were self-serving.

Exh. 1-A : JOINT COUNTER-AFFIDAVIT OF RAMON G.


RODRIGUEZ and LYNDON R. MONDAY is admitted as to
its existence but denied as to the truthfulness of the contents
thereof.

Exh.

2-A,

and

FLORENTINO,

SIGNATURES

RAMON

RODRIGUEZ

OF

MICHAELO

AND

LYNDON

MONDAY is admitted.

Exh. 3 : LOG BOOK OF THE PYRA DICE LODGE is admitted as


to its existence but denied as to the truthfulness of the contents
thereof;
A clear perusal of the log book would show that it is preposterous as
what Lodge would keep a log book of its clientele. It is nothing but
hearsay evidence and only serves to provide a twisted form of
evidence for the defense. It is self-serving as it is irrelevant.
Exh.

PHOTOGRAPH

OF

COMPLAINANT

and

RESPONDENT MICHAELO FLORENTINO Is admitted only


as to its existence but is denied as to the purpose to which it is
being offered. The complainant does not have any romantic
affiliation with the accused.

Exh. 5 : CERTIFIED TRUE COPY OF ANNUAL INCOME TAX


RETURN
SUICO

WITH

RECEIPT

OF

COMPLAINANT

JOAN

1 Is admitted as to its existence but denied as to the truthfulness


of the contents thereof. In fact, the said document is not even
original and only brings us to question as to how the defense
got a hold of a copy of such document if not being forcibly taken
from the complainant which only proves our allegations.
2 Denied as to the purpose to which it is being offered.

Exh.

CERTIFIED

TRUE

COPY

OF

NSO

BIRTH

CERTIFICATE OF JOAN SUICO is admitted as to its existence


but denied as to the purpose to which it is being offered. In fact, the
said document is not even original and only brings us to question as
to how the defense got a hold of a copy of such document if not
being forcibly taken from the complainant which only proves our
allegations

Exh. 7 : AFFIDAVIT OF LOSS OF LYNDON MONDAY

is

admitted as to its existence but denied as to the truthfulness of the


contents thereof and as to the purpose to which it is being offered. It
is self-serving and irrelevant.
RESPECTFULLY SUBMITTED.
Digos City, Davao del Sur, Philippines, this 7th day of May 2015.

ATTY. ANNA MAE S. REYES


Private Prosecutor
MCLE Compliance No. 3 0000545/ 08-21-08
MCLE Compliance No. 4 0000673/11.04.2010
IBP Roll No. 41499
TIN
No. 143-089-251
PTR No.3525808/01-04-2011/Hagonoy, Davao del Sur
IBP O.R.No. 723578 / 12-01-2011/ Digos City
Cor. Magsaysay & Lapulapu Sts. Digos City

Copy furnished:
Atty. Pearl Canada
Counsel for the Defense