Republic of the Philippines,

REGIONAL TRIAL COURT

12th Judicial Region
Branch 61
Kidapawan City

PEOPLE OF THE PHILIPPINES, CRIMINAL CASE NO

Plaintiff, 3838-2016

-versus- -for-

ENRICO ANISTAL DELA PIEZA, VIOLATION of

Accused . SECTION 5,
ART II of RA 9165
X---------------------------------------x
PEOPLE OF THE PHILIPPINES, CRIMINAL CASE NO
Plaintiff, 3839-2016

-versus- -for-

ENRICO ANISTAL DELA PIEZA, VIOLATION of

Accused . SECTION 11,
ART II of RA 9165
X---------------------------------------x

COMMENTS/OBJECTIONS TO THE PROSECUTION’S

JOINT FORMAL OFFER OF EVIDENCE/EXHIBITS

COMES NOW, the ACCUSED, through the

undersigned counsel, and unto this Honorable Court, most
respectfully submits these comments and objections to the
prosecution’s formal offer of evidence, to wit:

1. EXHIBIT “A” – Affidavit of Apprehension of PO3

Mebeposet Himalaya;
Defense objects to the admissibility of the above-
exhibit on the ground that it is self-serving.

Comments and Objections to Joint Formal Offer of Exhibits

People vs Enrico Anistal Dela Pieza
Criminal Cases Nos 3838-2016 and 3839-2016
Page 1 of 3
2. EXHIBIT “B” – Affidavit of PO2 Jonathan Colcol;
Defense objects to the admissibility of the above-
exhibit on the ground that it was not identified in court;

3. EXHIBIT “C” – PDEA Certificate of Coordination;

Defense objects to the admissibility of the above-
exhibit because it is not an original copy;

4. EXHIBIT “D” – Extract of Police Blotter;

No comment as to the existence of the above exhibit;

5. EXHIBIT “E” – Php 500 bill;

No comment as to the existence of the above-exhibit;

6. EXHIBIT “F” to “F-1”– Inventory of Evidence/

Property;
No comment as to the existence of the above-exhibit;

7. EXHIBIT “G”– Request for Laboratory Examination;

No comment as to the existence of the above-exhibit;

8. EXHIBIT “H” to “H-1” – Chain of Custody;

No comment as to the existence of the above-exhibit;

9. EXHIBIT “I” – Chemistry Report No. PC-D-438-

2016;
No comment as to the existence of the above-exhibit;

Comments and Objections to Joint Formal Offer of Exhibits

People vs Enrico Anistal Dela Pieza
Criminal Cases Nos 3838-2016 and 3839-2016
Page 2 of 3
10. EXHIBIT “J” – Photographs;
No comment as to the existence of the above-exhibit;

11. EXHIBIT “K” – One piece heat sealed plastic sachet

marked EAD;
12. EXHIBIT “K” – One piece heat sealed plastic sachet
marked EAD-1;
No comment as to the existence of the above-exhibits
but notes the material difference in the weight as reflected
in the Police Blotter in comparison with the Chemistry
Report;
13. EXHIBIT “M” – White envelope;
14. EXHIBIT “N” – Brown envelope
No comment as to the existence of the above-exhibits;

RESPECTFULLY SUBMITTED.
Kidapawan City, Philippines, September 8, 2017.

Assisted By:
PUBLIC ATTORNEY’S OFFICE
Kidapawan District Office
Hall of Justice, Kidapawan City

By:

JENNIFER D. DE MESA
Public Attorney II
Roll of Attorney No. 64004
IBP Lifetime No. 952280/January 13, 2016/Sultan Kudarat
MCLE Compliance No V - 00023489
PTR Exempt
Copy Furnished:
Pros. Eugene S. Seron By: _____________
City Prosecution Office Date: _____________
Kidapawan City

Comments and Objections to Joint Formal Offer of Exhibits

People vs Enrico Anistal Dela Pieza
Criminal Cases Nos 3838-2016 and 3839-2016
Page 3 of 3