REPUBLIC OF THE PHILIPPINES

METROPOLITAN TRIAL COURT

NATIONAL CAPITAL JUDICIAL REGION
Branch 98
MANDALUYONG CITY

PEOPLE OF THE PHILIPPINES,

Plaintiff,
Crim. Case No. 116931
-versus-
For: Slight Physical Injuries
CELSO ALIBIO,
SUSAN CATACUTAN,
Accused.
x-----------------------------------------------x

COMMENTS / OBJECTIONS TO THE

FORMAL OFFER OF EVIDENCE

COMES NOW, Accused, through the Public Attorney’s Office by

the undersigned counsel and unto this Honorable Court, most
respectfully objects to the Prosecution’s Formal Offer of Evidence on the
following grounds to wit:

EXHIBITS “A” and its submarking

Comment / Objections: Objection is interposed as this exhibit is

merely SELF-SERVING, IMMATERIAL,
and IRRELEVANT.

The Defense interposes that there are

inconsistencies between the testimony
of GILDA CANETE and the injuries
medically examined and treated by the
medical doctor.

EXHIBIT “B”

Comment / Objections: The Defense interposes that this exhibit

violates the “best evidence rule”. The
original of which was not presented in
open court. The counsel de oficio had no
 COMMENTS/ OBJECTIONS TO THE
FORMAL OFFER OF EVIDENCE
People vs. Celso Alibio, Susan Catacutan
Crim. Case No. 116931
X---------------------------------------------------------X

opportunity to compare the photocopy

thereof with the original.

EXHIBIT “C” and its submarkings

Comment / Objections: The Defense interposes that this exhibit

is SPECULATIVE as there is no proof as
to the ultimate cause of the findings /
diagnosis of the medical doctor.

The Defense also interposes that this

exhibit contradicts and shows apparent
inconsistencies between the testimony
of GILDA CANETE as to the injuries that
she sustained, and the findings/
diagnosis of the medical doctor.

EXHIBIT “D” and its submarkings

Comment / Objections: Objection is interposed as this exhibit is

merely SELF-SERVING, IMMATERIAL,
and IRRELEVANT.

The Defense interposes that the same

was not authenticated by the person
who took the pictures thereof.

EXHIBIT “E” and its submarkings

Comment / Objections: Objection is interposed as this exhibit is

merely SELF-SERVING, IMMATERIAL,
and IRRELEVANT.

The Defense interposes that there are

inconsistencies between the testimony
of GILDA CANETE and the injuries
medically examined and treated by the

2
 COMMENTS/ OBJECTIONS TO THE
FORMAL OFFER OF EVIDENCE
People vs. Celso Alibio, Susan Catacutan
Crim. Case No. 116931
X---------------------------------------------------------X

medical doctor.

EXHIBIT “F” and its submarkings

Comment / Objections: Objection is interposed as this exhibit is

merely SELF-SERVING, IMMATERIAL,
and IRRELEVANT.

The Defense interposes that there are

inconsistencies in the testimony of
SUSAN TELEG, thus, raising doubt on
the credibility of said witness.

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed

that the Honorable Court in its resolution consider the foregoing
comments / objections with respect to the Prosecution’s formal offer of
evidence.

RESPECTFULLY SUBMITTED.

9 June 2017, City of Mandaluyong.

PUBLIC ATTORNEY’S OFFICE

Ground Floor, Hall of Justice Bldg.
Maysilo Circle, Mandaluyong City
By:

KERSTIN KAYE L. ILAGAN

Public Attorney I
Roll of Attorneys No. 65685
IBP No. 015641 (Manila III) (Lifetime) – 01/09/2017

Copy Furnished:
ACP CHRISTINE DIANNE V. SONGCO (by personal service)
The Honorable Public Prosecutor, MeTC Branch 98
Office of the City Prosecutor
3rd Flr. Hall of Justice Bldg.
Mandaluyong City