Republic of the Philippines

REGIONAL TRIAL COURT OF NEGROS ORIENTAL

7th Judicial Region
Branch _____
Family Court Designate
Dumaguete City

PEOPLE OF THE PHILIPPINES, CRIMINAL CASE No. _____

Plaintiff,

- versus - FOR: Violation of Section 5(a)

Of R.A. No. 9262
RAMIL SACASAN y CATUBIG,
Accused.
x----------------------/

COMMENTS/OBJECTIONS
(To the Prosecution’s Formal Offer of Evidence)

ACCUSED, by counsel, respectfully comments and/or objects to the Formal Offer

of Evidence of the Prosecution as follows:

EXHIBIT DOCUMENT COMMENT/OBJECTION

Admits the existence and authenticity of said
exhibit, but objects to the purpose for which it
was offered for being irrelevant and
Photocopy of Medical
misleading.
certificate issued by Dr.
“A” to Bevito Gonazaga, MHO,
The said Medical Certificate was not issued
“A-1” Vallehermoso, Negros
by an authorized government examining
Oriental, dated June 8,
physician as required by law. Also, the
2015
testimony of the witness is bereft of any
indication where she had positively identified
said document during her direct testimony.
Admits the existence and authenticity of said
Photocopy of the exhibit, but objects to the purpose for which it
Ultrasound Result/Finding was being offered for being misleading.
“B” to
issued by Dr. Samuel S.
“B-1”
Martinez, M.D. dated June The testimony of the witness is bereft of any
8, 2015 indication where she had positively identified
said document during her direct testimony.
Police Report representing Admits the existence and authenticity of said
Extract Copy of the Police exhibits, but objects to the purpose for which
“C” to Blotter Entry NO. 012, it was offered for being irrelevant.
“C-1” Page Nr. 8, dated June 8,
2015, issued and signed The Police Blotter does not prove that the
by PO2 Christy P. Aquino, alleged mauling incident as claimed by the
 PNP, WCPD, PNCO complainant did exist; it is just a record at the
police station based on the statements of
herein complainant.
Denies the existence of said exhibit, and
objects to the purpose for which it was
offered for being misleading.

The photographer who took the pictures was

Copy of pictures showing
the injuries sustained by
“D”
the victim with PO2
Christy P. Aquino
not presented and was unable to identify the
same. In Sison v. People 250 SCRA 58, the
Supreme Court said: The rule in this
jurisdiction is that photographs, when
presented in evidence, must be identified by
the photographer as to its production and
testified as to the circumstances under which
they were produced. x x x Photographs,
however, can be identified also by any other
competent witness who can testify to its
exactness and accuracy.

No photographer or any other competent

witness, even the complainant herself,
testified to its exactness and accuracy.

WHEREFORE, premises considered, the ACCUSED respectfully prays to this

Honorable Court to deny the admission of the foregoing exhibits objected to for the
reasons stated above.

Other reliefs just and equitable are likewise prayed for under the premises.

Dumaguete City, Philippines, this 11th day of January 2016.

Atty. CAMAD C. ALI, JR.

Room 6, Novotel Building, Perdices St., Dumaguete City
PTR No. 123; Mar. 31, 2016, Dumaguete City
IBP No. 123; Mar. 31, 2016, Dumaguete City
Roll NO. 123; May 2, 2012
Tel No. (035) 226-1234
MCLE No. 12345; May 10, 2013
COUNSEL FOR THE ACCUSED

Copy furnished through personal service to:

RUEL YGONA AGUILAR

Asst. Provincial Prosecutor
PPO, Dumaguete City, Negros Oriental

Received by : _________
Date : _________