Republic of the Philippines

REGIONAL TRIAL COURT

National Capital Region, Judicial Region
Quezon City, Branch 103

PEOPLE OF THE PHILIPPINES, Criminal Case No. XV-04-INQ-

Plaintiff, 182-16411
–versus- For: Violation of Sec. 3 of P.D.
1866, as amended by R.A. 9516
GIANNO BATONGBAKAL A.K.A. “MANONG”
“MANONG G.”
Accused.

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COMMENT TO THE FORMAL OFFER OF EVIDENCE

OF THE PROSECUTION
The ACCUSED, with the assistance of the, through the undersigned counsel and unto this
Honorable Court, most respectfully comments and/or objects to the admission of the
Prosecution’s Formal Offer of Documentary Evidence to wit:
ACCUSED objects to the formal offer of the Joint Affidavit of the arresting officers
dated August 10, 2020, marked as Exhibit “A” with sub-markings “A-1”, “A-2”,”A-3”. The
Joint Affidavit of the Arresting Officers is admissible as evidence due to the reason that it was
never identified and existed during the presentation of the respective direct testimonies. There is
no basis for its admissibility thus making its purpose moot and unwarranted.
The ACCUSED further comments and/or objects to the following:
EXHIBITS COMMENT

“B” The accused admits the existence of this

Grenade Rifle BT bearing the serial number
M-76B-AA0055-8
object evidence.
However, the accused objects to the purpose
to wit: “as part of the testimony of
prosecution witnesses SPO2 Ruel Rigil, PO3
Judy Nicomedes and Po2 Jeffrey Agbayani,
because the testimony being inexistence has
no practical use and value to the case.

“C” to “C1” Accused admits the genuineness and due

 execution of this document as it is a public
Certification issued by PO3 Eugene Argas document and forms part of public record,

However the accused objects to their

admissibility with respect to the purpose for
which they are being offered for being
IMMATERIAL & IRRELEVANT because
the accused was illegally arrested.

PRAYER

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 2nd day of September 2020 at Quezon City Philippines.

ATTY. JANE J. DOE 

                           Until December 31, 2023 
                            Roll No. 12345, TIN. 123-456-789-000 
                              PTR No. 1234567 01/02/2020/Q.C. 
                              IBP Lifetime No. 123456 / 01/02/2020/Q.C. 
                            MCLE COMP V-0012345 01/06/2020 
                            AOM MATTER No. NP-012 (2020-2021)

Copy furnished: (by Electronic Mail)

SPO2 RUEL RIGIL, PO4 JUDY NICOMEDES and PO2 JEFFREY AGBAYANI
QCPD, District Special Operation Unit, Camp P/M Gen. Tomas B. Karingal, Sikatuna Village,
Quezon City.

THE BRANCH CLERK OF COURT

Regional Trial Court National Capital Judicial Region
Quezon City, Branch 103

THE HONORABLE ASSISTANT CITY PROSECUTOR

Office of the City Prosecutor
Hall of Justice, Quezon City
 EXPLANATION

The foregoing Comment to the Formal Offer of Evidence of the Prosecution was furnished to the
Witnesses, Clerk of Court, and to the Assistant City Prosecutor through electronic mail due to
lack of personnel to effect personal service.
                                      
ATTY. JANE J. DOE 
Counsel for the Defense