Republic of the Philippines REGIONAL TRIAL COURT 11th Judicial Region Branch 21 Bansalan, Davao del Sur
PEOPLE OF THE PHILIPPINES, PHILIPPINES, CR.32 C-S& $2 XXI-149 !1"# Plaintif, - versus -
MICHAELO FLORENTINO, LYNDON MONDAY, AND RAMON RODRIGUEZ
%$R' ROBBER$ %ITH RAPE
Accused.
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COMMENT OR OPPOSITION TO THE FORMAL OFFER OF EXHIBITS Coe Coes s no! the STATE, STATE, through the undersigned counsel and unto this this "ono "onora rabl ble e Court ourt,, ost ost res respec pectful tfull# l# sub subit its s this his Co Coen entt or $pposition to the %oral $ffer of &xhibits filed b# the defense and avers'
1
(hat the undersigned counsel received an $rder fro this "onorab "onorable le Court Court directi directing ng the unders undersigne igned d counsel counsel to file file his coent to the Defense)s %oral $ffer of &xhibits*
+
(hat in relation thereto, P-.(.%% through the undersigned counsel for!ards the follo!ing coents or oppositions'
Exh. “1” : COUNTER COUNTER-AF -AFFIDA FIDAVIT VIT OF MICHAEL MICHAELO O FLOREN FLORENTIN TINO O 0 is aditted as to its existence but is obected as to the purpose to !hich it is being offered2
1 -s can be be gleaned gleaned in the aff affida idavit vit,, the state stateent ents s and clais clais of of the accused, 3r2 %lorentino, !ere self4serving2
Exh. “1-A” : JOINT COUNTER-AFFIDA COUNTER-AFFIDAVIT VIT OF RAMON G. 0 is aditted as to RODRIGUEZ and LYNDON R. MONDAY 0 its its exis existe tenc nce e but but deni denied ed as to the the trut truthf hful ulnes ness s of the the cont conten ents ts thereof2
Exh.
“-A,
!
and
FLOR FLOREN ENTI TINO NO,,
C”
:
SIGN SIGNA ATURE TURES S
RAM RAMON
RODR RODRIG IGUE UEZ Z
OF
MICH MICHAE AEL LO
AND
LYNDO YNDON N
0 is aditted2 MONDAY 0
Exh. “"” : LOG !OO# OF THE PYRA DICE LODGE 0 is aditted as to its existence but denied as to the truthfulness of the contents thereof*
- clear clear perusal of the log boo5 !ould sho! that it is preposterous as !hat odge !ould 5eep a log boo5 of its clientele2 .t is nothing but hearsa# evidence and onl# serves to provide a t!isted for of evidence for the defense2 .t is self4serving as it is irrelevant2
Exh.
“$”
:
PHOTOGRAPH
OF
COMPLAINANT
and
RESPONDENT MICHAELO FLORENTINO 0 .s aditted onl# as to its existence but is denied as to the purpose to !hich it is bein being g offe offere red2 d2 (he cop copla lain inan antt does does not not have have an# an# roa roant ntic ic affiliation !ith the accused2
Exh. Exh. “%” : CERTIFIED TRUE COPY OF ANNUAL INCOME TA&
RETU ETURN SUICO 0
'ITH
RECEI CEIPT
OF
COM COMPLA PLAINAN NANT
JOAN
1 .s aditt aditted ed as to its its existe existence nce but but denied denied as to the truthf truthfuln ulness ess of the contents thereof2 .n fact, the said docuent is not even original and onl# brings us to 6uestion as to ho! the defense got a hold of a cop# of such docuent if not being forcibl# ta5en fro the coplainant !hich onl# proves our allegations2
+ Denied Denied as to to the purpo purpose se to to !hich !hich it is is being being offe offered2 red2
Exh.
”(”
:
CERTIFIED
TRUE
COPY
OF
NSO
!IRTH
CERTIFICATE CERTIFICATE OF JOAN SUICO 0 is aditted as to its existence but denied as to the purpose to !hich it is being offered2 .n fact, the said docuent is not even original and onl# brings us to 6uestion as to ho! the defense got a hold of a cop# of such docuent if not being forcibl# ta5en fro the coplainant !hich onl# proves our allegations
Exh. xh. ”)” : AFFIDAVIT OF LOSS OF LYNDON MONDAY 0 is aditted as to its existence but denied as to the truthfulness of the contents thereof and as to the purpose to !hich it is being offered2 .t is self4serving and irrelevant2
R&SP&C(%78 R&SP&C(%7 8 S7B3.((&D2 S7B3.(( &D2
Digos Cit#, Davao Davao del Sur, Philippines, this 9 th da# of 3a# +:1;2
ATT$. ATT$. ANNA MAE S. RE$ES RE$E S Private Prosecutor 3C& Copliance o2 < 0 ::::;;/ :>4+14:> 3C& Copliance o2 0 ::::?9@4+;1 P(R o2<;+;>:>/:14:4+:11/"agono#, o2<;+;>:>/:14:4+:11/"agono#, Davao del Sur .BP $2R2o2 9+<;9> / 1+4:14+:11/ Digos Cit# Cor2 3agsa#sa# A apulapu Sts2 Digos Cit#
Cop# furnished' -tt#2 -tt#2 Pearl Canada Counsel for the Defense
