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Republic of the Philippines

REGIONAL TRIAL COURT


12th Judicial Region
Branch 26, Wao, Lanao del Sur

PEOPLE OF THE PHILIPPINES, Criminal Case NO. 18-444-W


Plaintiff,
–versus- For: Violation of Sec. 5 of Art.
2 of R.A. 9165
SAQUIO MAESTRADO BALICAO, JR.,
Accused.

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PEOPLE OF THE PHILIPPINES, Criminal Case No. 18-445-W


Plaintiff,

-versus- For: Violation of Sec. 11, Art.


II of R.A. 9165
SAQUIO MAESTRADO BALICAO, JR.,
Accused.

COMMENT TO THE FORMAL OFFER OF EVIDENCE


OF THE PROSECUTION
The accused, with the assistance of the Public Attorney’s Office, through the
undersigned counsel and unto this Honorable Court, most respectfully submits his
Comment to the Formal Offer of Evidence of the Prosecution, to wit:
EXHIBITS COMMENT

“A” and sub-markings Accused admits only the existence of said


affidavit. They are objected for being self-
Affidavit of PO1 Cyrus Hisona Romasanta serving. Further, they do not prove the
alleged buy-bust operation.

“B” and sub-markings Accused objects to its admissibility as


secondary evidence considering that the
Buy-bust money original buy-bust money has not been
shown to be lost, destroyed, or that it
cannot be produced in court. Therefore,
the exhibit is INCOMPETENT.

“C” and sub-markings Accused admits only the existence but


objects to their admissibility with respect
Certificate of Coordination to the purpose for which they are being
offered for being self-serving.

“D” and sub-markings Accused admits only the existence but


objects to their admissibility with respect
Affidavit of Arresting Officer to the purpose for which they are being
offered for being self-serving. Further,

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they do not prove the circumstances that
led to the accused’ arrest.

“E” and “E-1” Accused DENIES their existence and


objects to their admissibility with respect
Certificate of Inventory to the purpose for which they are being
offered for being IMMATERIAL &
IRRELEVANT because the prosecution
failed to show that the mandatory
provision of Sec. 21 of R.A. 9165 was
faithfully complied with.

“F” and sub-markings Accused objects to these exhibits as it


appears that they were NOT
Chain of Custody IDENTIFIED in court.

“G” and sub-markings Accused objects to these exhibits as it


appears that they were NOT
Chemistry Report No. D-188-2018 IDENTIFIED in court.

“H” and sub-markings Accused objects to these exhibits as it


appears that they were NOT
Chemistry Report No. D-189-2018 IDENTIFIED in court.

WHEREFORE, premises considered, it is most respectfully prayed of this


Honorable Court that the foregoing comment to the exhibits offered by the prosecution
be considered in resolving the Prosecution’s Formal Offer of Evidence.
Respectfully submitted this 8th day of February 2019 at Wao, Lanao del Sur.

PUBLIC ATTORNEY’S OFFICE


Wao, Sub-district Office
Wao, Lanao del Sur

By:

ATTY. JOANIE CHARMAINE B. HERNANDEZ


Public Attorney I
Roll of Attorney’s No. 67110
IBP No. 098334, 1/10/2019
MCLE: Complied but no certification yet.

Copy furnished: (by personal service)

ATTY. HAROUN BIN OMAR E. MANABILANG


Assistant Provincial Prosecutor
OFFICE OF THE PROVINCIAL PROSECUTOR
Hall of Justice, Marawi City, Lanao del Sur

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