REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
BRANCH 33, TAGUIG CITY

KRIS AQUINO,
Plaintiff,

GROUP 3 PLAINTIFF
Kristie Auriel Enriquez
Nancy Martinez
Jonathan Nepomuceno
DRAFT COPY FOR
CLASS USE ONLY

CIVIL CASE NO. 189-09

FOR: DAMAGES

- versus
MELDY MARCOS,
Defendant.
X------------------------------X

COMMENT ON THE FORMAL OFFER

OF DEFENDANTS EVIDENCE
PLAINTIFF, thru undersigned counsel, in the above-entitled case,
and unto this Honorable Court most respectfully manifests her
comments and objections to the Defendants Formal Offer of Evidence for
the following reasons:
EXHIBIT
Exhibit 1-1

DESCRIPTION
COMMENT/OBJECTION
Official Receipt of Tiffany Plaintiff admits the same
Circlet
Triple
Drop with reservation as to its
Necklace
genuineness
and
due
execution.

Exhibit 1-2

Official Receipt of Frank

Gehry Morph Earrings
Official
Receipt
of
Diamonds by the Yard
Bracelet
Official Receipt of Tiffany
Metro Ring
Official Receipt of Lucinda
Ring
Hotel Security Camera

Exhibit 1-3

Exhibit 1-4
Exhibit 1-5
Exhibit 2

Same as above.
Same as above.

Same as above.
Same as above.
Exhibit 2 should not be

Footage

Exhibit 3

Official Incident Report

From Hotel Security

admitted for being irrelevant

and merely circumstantial.
The mere fact of being
recorded as the only person
entering the suite does not
sufficiently
prove
that
Plaintiff was the one who
took the jewelry as the exact
time and circumstances of
the loss have not been
conclusively established.
Plaintiff admits the same but
with reservation as to its
genuineness
and
due
execution and comments that
the
same
is
merely
circumstantial
and
insufficient to establish that
Defendant did not publicly
impute a crime to Plaintiff
and utter defamatory words
against the latter in front of
the Brides wedding party in
Suite 1051 on 10 October
2009.

PRAYER
WHEREFORE, premises considered, it is most respectfully prayed
that this Honorable Court take cognizance of the matters herein set forth
and exclude the object evidence identified above.

Other reliefs just and equitable are likewise prayed for.

Makati City for the City of Taguig, 4 February 2010.

NEPOMUCENO ENRIQUEZ MARTINEZ (NEM) LAW OFFICE

6th and 7th Floors, ABC Building,
Makati Avenue cor. Sen. Gil Puyat Avenue
Makati City
(02) 895-1234

By:
JONATHAN NEPOMUCENO
Roll of Attorney No.12345
P.T.R. No.0989524, 01/07/2018, Makati City
I.B.P. Lifetime Member No. 735167; Makati Chapter
jonnepomuceno@nemlaw.com.ph

KRISTIE AURIEL ENRIQUEZ

Roll of Attorney No. 41888
P.T.R. No. 0989525, 01/07/2018 Makati City
I.B.P. No. 735168, 01/08/2018, Makati Chapter
kristieenriquez@nemlaw.com.ph

NANCY MARTINEZ
Roll of Attorney No. 41777
P.T.R. No. 0989526, 01/07/2018, Makati City
I.B.P. No. 735169, 01/07/2018, Makati Chapter
nancymartinez@nemlaw.com.ph

MCLE Compliance No. 4939170

plz@flazlaw.com ; (02) 432-5432 local 111

Copy Furnished By Personal Service:

ATTY. LAURICE MARIE ANGELA AUSTRIA
8th Floor, Strata 4000 Towers,
Emerald Ave., Pasig City
(02) 631-9801 to 04

Receipt No. ____________

PROOF OF SERVICE

I, Speedy Gonzales, messenger of Atty. Jonathan Nepomuceno, herein

counsel for Plaintiff Kris Aquino, hereby certify that I personally delivered
Plaintiffs Comment to Defendants Formal Offer of Evidence dated 4
February 2010 to Atty. Laurice Marie Angela Austria, counsel for the
Defendant, with address at 8th Floor, Strata 4000 Towers, Emerald Ave.,
Pasig City. The Comment to Defendants Formal Offer of Evidence was
received by counsel personally.

SPEEDY GONZALES
SUBSCRIBED AND SWORN to before me this 4TH day of February 2010 at
Makati City, Metro Manila, personally appeared affiant SPEEDY
GONZALES and exhibiting to me his Drivers License with License No. N12345, issued at the Quezon City on 14 February 2008.

Doc. No.______;
Page No.______;
Book No.______;
Series of 2010