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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT


NATIONAL CAPITAL JUDICIAL REGION
BRANCH 203
CITY OF MUNTINLUPA

PEOPLE OF THE PHILIPPINES, Crim. Case. No. 10-288


Plaintiff,

-versus- FOR: Viol. of Sec. 5,


Art. II, R.A. 9165

LENIE GUTIEREZ y MARANAN


Accused.
x-------------------------------------------x
PEOPLE OF THE PHILIPPINES, Crim. Case. No. 10-289
Plaintiff,

-versus- FOR: Viol. of Sec. 14,


Art. II, R.A. 9165

SEVERINO AREVALO y MANUEL


And RODEL ALVAREZ y ESPER
Accused.
x-------------------------------------------x

COMMENT/OPPOSITION TO THE
FORMAL OFFER OF DOCUMENTARY EXHIBITS

COMES NOW, the accused through undersigned public


attorney, unto this Honorable Court, most respectfully files her
Comment/Opposition to the Prosecutions Formal Offer of Evidence
and states that:

EXHIBIT EVIDENCE REMARKS


A and submarkings Pre-operation report Exhibit A and its
A-1 and A-2 adjuncts are admitted
but not for the
purpose for which
they are offered.
B and submarkings Coordination form Exhibit B and its
B-1 to B-5 adjuncts are admitted
but not for the
purpose for which
they are offered.
C Photocopy of the buy- Exhibit C is admitted
bust money but not for the
purpose for which it is
offered.

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D and submarking Certificate of Exhibit D is being
D-1 Inventory objected to for non-
compliance with the
requirements of Sec.
21, R.A. 9165 and its
IRR.

It is likewise being
objected to for being
partial hearsay, the
signatures of the
arresting officers not
having been identified
in open court.
E and submarkings Request for Exhibit E and its
E-1 to E-5 Laboratory adjuncts are admitted
examination but not for the
purpose for which it
was offered.
F Physical Science Exhibit F is admitted
Report No. D-186- but not for the
10S purpose for which it
was offered.
G and submarkings Joint Affidavit of Exhibit G and its
G-1 and G-2 Arrest adjuncts are being
objected to for
material
inconsistencies
between the
allegations in the
document and the
open-court testimony
of the witnesses, and
likewise for being
self-serving.
H Photograph of Exhibit H is being
Accused Lenie objected to for being
Gutierez non-compliant with
Sec. 21, R.A. 9165.
H-1 Photograph of the Exhibit H-1 is being
evidence seized from objected to for being
the accused and the non-compliant with
buy-bust money. Sec. 21, R.A. 9165.
H-2 Photograph of Exhibit H-2 is being
Accused Rodel objected to for being
Alvarez non-compliant with
Sec. 21, R.A. 9165.
H-3 Photograph of Exhibit H-3 is being

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Accused Severino objected to for being
Arevalo non-compliant with
Sec. 21, R.A. 9165.
I Booking and Exhibit I is admitted
Information Sheet but not for the
purpose for which it
was offered.
J and submarkings Withdrawal slip of the Exhibit J and
Forensic Chemist submarkings are
from the Evidence admitted but not for
Custodian the purpose for which
it was offered.
K Pertinent excerpt of Exhibit K is admitted
the logbook but not for the
purpose for which it
was offered.
L and submarkings Object evidence; heat Exhibit L and
sealed transparent submarkings are
sachet with white being objected to for
crystalline substance being planted
marked as LG evidence and self-
weighing 0.04 gram. serving.
M and submarkings Object evidence; Exhibit M is objected
Security seal to for being self-
serving.
N and submarkings Object evidence; Exhibit N is objected
Aluminum foil with to for being planted
marking PS1 with evidence and self-
traces of white serving.
crystalline substance
O and submarkings Object evidence; Exhibit O is being
Improvised aluminum objected to for being
foil tooter marked as planted evidence and
PS2 with traces of self-serving.
white crystalline
substance
P Object evidence; Exhibit P is admitted
disposable lighter but not for the
marked as PS3 purpose for which it
was offered.
Q Object evidence; One Exhibit Q is being
500-peso bill with objected to for being
serial no. MQ721556 planted evidence and
used as buy-bust self-serving.
money

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PRAYER

WHEREFORE, premises considered, it is respectfully prayed


that the abovementioned Comment/Opposition of the Defense be
duly noted and favorably considered by this Honorable Court.

Muntinlupa City, 10 October 2016.

Department of Justice
PUBLIC ATTORNEYS OFFICE
Muntinlupa District Office
Ground Floor, Muntinlupa Hall of Justice
National Road, Tunasan, Muntilupa City

KRISTINE DRAEI V. DUMALANTA


Public Attorney II
Roll No. 65497
IBP No. 1040697 (PPLM) May 16, 2016
PTR No. 2247067 June 21, 2016, Muntinlupa City
MCLE Compliance No. n/a

Copy Furnished

HON. NOEMI L. SUAVILLO-MACABABBAD


Office of the City Prosecutor
Muntinlupa City

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