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Republic of the Philippines

Department of Justice
National Prosecution Service
OFFICE OF THE PROVINCIAL PROSECUTOR
Province of Samar

MA. LUCIA G. GABILLETE NPS DOCKET NO. VIII-09-INV-


23L-
Complainant, 01339

-versus- For: Alarm and Scandal


under Art.155 of the RPC

JUANITO P. LLANTOS JR.,


Respondent.
x---------------------------------x

JUANITO J. PIEGO NPS DOCKET NO. VIII-09-INV-23L-


Complainant, 01339

-versus- For: DIRECT ASSAULT UNDER


ART.148 OF THE RPC

JUANITO P. LLANTOS JR.,


Respondent.
x---------------------------------------x

COMMENT/OPPOSITION
(To the Motion to Add Witness)

COMES NOW respondent thru undersigned counsel unto the Honorable


Office respectfully states: that-

1. In their motion, complainants prayed that, to wit:

Xxx
IN VIEW OF THE FOREGOING PREMISES, it is respectfully
prayed for that herein motion to add witnesses be considered for violation
of Direct Assault under Article 148 of the RPC and Alarm and Scandal
under Article 155 of the RPC.

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2. With due respect, the respondent does not subscribe to such motion:
Reasons-

2.1 A reading of the instant motion of the herein


complainants inarguably shows no factual and legal basis. The
allegations of the additional witnesses of the complainants which were
also members of their party list and their relatives merely relied on the
complainants' assertions. Stated differently, the contentions in their
respective affidavits of all the additional witnesses are mere rehashed
of the complaint-affidavits submitted by the complainants;

2.2 It is also worthy of note that a careful perusal of the


affidavits of the additional witnesses does not have any material or
relevant pieces of evidence to prove their claims thereby making it
hearsay and self-serving;

2.3 Thus, it is now safe to say that the allegations of the


additional witnesses are being pure lies, tainted concoctions, and
evident fabrications the truth of the matter already stated in the
respondent’s counter-affidavits.

PRAYER

WHEREFORE, premises considered, it is respectfully prayed that the


complainant's “Motion to Add Witness,” for utter lack of merit, be DENIED.

Catbalogan City, 22 February 2024.

ATTY. DEMETRIO MEDINO J. ACUBA


Counsel of the Respondent
G/F Laohoo Bldg., San Bartolome St.
Brgy. 3, 6700 Catbalogan City, Samar
IBP Official Receipt No.382473
PTR. No. 382473 Catbalogan City 1.3.24
Roll of Attorneys No. 71321
MCLE Compliance No. VII-0019383

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CC: (By Personal Service)

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