Republic of the Philippines

REGIONAL TRIAL COURT

First Judicial Region
Branch 3
Baguio City

MARIA ASUNCION A.
BOTENGAN,
Plaintiff, Civ. Case No. 5516-R

- versus -

BALTAZAR WANSON , et al,

Defendants.
x---------------------------x

COMMENT
ON THE FORMAL OFFER OF EVIDENCE

WITH ALL DUE RESPECT TO THE HONORABLE COURT,

Defendants through counsel most respectfully submits this comment and in
support thereof alleges that:

1. EXHIBITS “A” is being objected to for being not testified to and

identified by the parties of the alleged Trust Agreement. Likewise, it
was allegedly executed in the absence of Defendant – Baltazar
Wanson who was then the legal husband of Melinda Wanson who
is a party to said instrument;

2. EXHIBITS “B” is likewise objected to for being not testified to and

identified by the person/s who prepared the same. The purpose
also is being objected since Plaintiff had never been in possession
of the real properties subject of the instant case as she was
admittedly living abroad;

3. EXHIBIT “C”, the purpose for which it is being offered is objected

as the same was not testified and identified to by the Plaintiff;
 4. EXHIBIT “D”, is being objected to as it does not prove transfer of
possession in favor of the Plaintiff but rather in favor of a certain
Elizabeth Solang. It does not contain and specify that the lot was
waived in favor of the Plaintiff.

PRAYER

WHEREFORE, premises all duly considered, it is most respectfully

prayed of this Honorable Court to note this comment on the formal offer of
evidence by the Defendant and its admissibility be denied.

Such other relief just and equitable under the premises are likewise
prayed for.

Baguio City, Philippines, this 9th day September, 2006.

Respectfully submitted.

PABLO F. WAGTINGAN, JR.

Counsel for the Defendants
Rm. 4 2/F Baguio Masonic Center,
180 Yandoc St., Baguio City,
Philippines
PTR No. 1643125:01-05-2006:B.C.
IBP No. 643559:01-05-2006:B.C.
ROLL No. 43631:05-05-1999:Mla.

NOTICE

THE BRANCH CLERK OF COURT

RTC-3
Baguio City,
Philippines

GREETINGS:

Please submit the foregoing pleading for the kind consideration and
approval of the Honorable Court immediately upon receipt hereof.

Thank you.
PABLO F. WAGTINGAN, JR.

Copy furnished:

ATTY. CHERYL D. YANGOT

Suite 512 Vellagio Tower,
Mezzanine Floor, Manahan Building,
Session Road, Baguio City,