You are on page 1of 5

Republic of the Philippines

REGIONAL TRIAL COURT


11th Judicial Region
Branch 38
Alabel, Sarangani Province
o00o
PEOPLE OF THE PHILIPPINES, CRIM. CASES NO. 2593-07
Plaintiff,
- versus - - for -

TONY OSANO, ILLEGAL POSSESSION OF


Accused. FIREARM AND EXPLOSIVES
X - - - - - - -- - - - - - - X

COMMENT ON THE FORMAL OFFER OF EXHIBIT

ACCUSED, through counsel and unto this Honorable Court, most


respectfully submit his comment/objection to the following exhibits offered in
evidence by the prosecution, to wit:

EXHIBIT NATURE COMMENT/OBJECTION

“A” and series Joint affidavit of Apprehension Self-serving; inconsistent; the


Orcajada/Balaba search and seizure was illegal;

“B” and series Certification from Firearm Irrelevant and immaterial since
and Explosive Unit subject firearm was issued by
Army to Alyn Lantingan

“C” Warrant of Arrest issued Admitted


in the name of the accused
for the crime of murder

“D” Cal 30 M1 Garand Subject weapon was issued to


Alyn Lantingan by the Army
and the same was taken from
his house by the arresting team;
“E” I clip for garand rifle Admitted;

“F” 8 rounds of ammunition Subject ammunition was illegally


for cal 30 confiscated by the police;

WHEREFORE, accused prayed that the foregoing exhibits be denied


admission and the object evidences were issued to Alyn Lantingan and illegally
confiscated by the police during the execution of the warrant.

Alabel, Sarangani Province. 04 November 2009.

PUBLIC ATTORNEY'S OFFICE


Department of Justice
Sarangani District Office
Alabel, Sarangani Province

BY:
SALVADOR G.TALAMAYAN
District Public Attorney
Copy Furnished: PPO
Copy furnished:

Office of the Provincial Prosecutor

"B" One (1) unit homemade pistol Inadmissible being the result
of illegal search and seizure;

"C" One (1) ammo for 5.56 mm Inadmissible being the result
of illegal search and seizure;

WHEREFORE, accused prayed that the foregoing exhibits be denied


admission.

Alabel, Sarangani Province. 12 December 2007.

PUBLIC ATTORNEY'S OFFICE


Department of Justice
Sarangani District Office
Alabel, Sarangani Province

BY:

SALVADOR G.TALAMAYAN
District Public Attorney

Copy furnished:

Office of the Provincial Prosecutor


“D” and series Sworn Statement of Lito Hearsay; not affirmed in open
Mariola Court;

“E” and series Sworn Statement of Hearsay; not affirmed in open


Simplicio Dacoy Court;

“E” and series Sworn Statement of Hearsay; not affirmed in open


Simplicio Dacoy Court;

“F” and series Death Certificate of the Hearsay; not affirmed in open
victim. Court;

WHEREFORE, accused prayed that the foregoing exhibits be denied


admission.

Alabel, Sarangani Province. 17 September 2007.

PUBLIC ATTORNEY'S OFFICE


Department of Justice
Sarangani District Office
Alabel, Sarangani Province
BY:

SALVADOR G.TALAMAYAN
District Public Attorney
Copy furnished: PPO

"D" and series Official Receipt Irrelevant and immaterial

“E” and series Deed of Sale of motorcycle Immaterial and irrelevant

“B” Affidavit of Jerry Matugina Hearsay and inconsistent;


immaterial; merely an
afterthought of the affiant

WHEREFORE, accused prayed that the foregoing exhibits be denied


admission.

Alabel, Sarangani Province. 08 August 2007.

PUBLIC ATTORNEY'S OFFICE


Department of Justice
Sarangani District Office
Alabel, Sarangani Province

BY:

SALVADOR G.TALAMAYAN
District Public Attorney

Page-1

Con't. of comment/sibunga ………..Page-2


--------------------------------------------------------------------------------------------------

PUBLIC ATTORNEY'S OFFICE


Department of Justice
Sarangani District Office
Alabel, Sarangani Province

BY:

SALVADOR G.TALAMAYAN
District Public Attorney

Copy furnished:

Office of the Provincial Prosecutor

Atty. Serafin S. Sinajon


City Hall Complex, Digos City.
Private Prosecutor

Explanation: Copy for the private prosecutor was sent thru registered mail by
reason of the distance from the Office of the Public Attorney to Digos City.

SALVADOR
G.TALAMAYAN
the addressee erk of Court
RTC, Branch 38
Alabel, Sarangani Province

Greetings:

Please submit the foregoing comment on the formal offer of exhibits


immediately upon receipt hereof for the kind consideration and approval of the
Honorable Court.

Alabel, Sarangani Province. 26 August 2005.

SALVADOR G.TALAMAYAN

Copy duly served personally:

Provincial Prosecutor's Office


Alabel, Sarangani Province
Date Received:___________
Time Received:___________

You might also like