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REPUBLIC OF THE PHILIPPINES

FOURTH JUDICIAL REGION


REGIONAL TRIAL COURT
BRANCH 7, BATANGAS CITY

PEOPLE OF THE PHILIPPINES,


Plaintiff,
Criminal Case No. 15933

-versus- for

ANALYN RAMOS y Peramo Violation of Secs. 5, Art.II,


Accused. of RA No. 9165

X------------------------------X

COMMENT / OBJECTION

COMES NOW, accused through the undersigned public attorney, unto this
Honorable Court, most respectfully submits her Comment to the Formal Offer of
Exhibits by the Prosecution, to wit:

Exhibit “A” and sub-marking (Sworn Statement of PO2 Christian Boy Aranza)

Comment: It is being objected to for being SELF-SERVING and SERIOUSLY


INCONSISTENT with the affiant’s testimony in Court.

Exhibit “B” and sub-marking (Letter Request for Laboratory Examination)

Exhibit “C” (Chemistry Report No. BD-013-09)

Comment: These 2 exhibits and their sub-markings are objected for being
IRRELEVANT as evidence. It was not convincingly proven that the accused was legally
arrested and neither was it proven that the subject matter of said documents were
confiscated from the accused.

Exhibit “D” (Spot Report)

Exhibits “D-1” to “D-3” (Pre-Operation Report)

Comment: Said two (2) documents are Objected for being INCOMPETENT
and INADMISSIBLE as evidence. There was NO Strong Proof that same were duly
coordinated with the PDEA.

Exhibit “E” and “E-1” (Photocopy of Police Blotter)

Comment: Objected to for being PURELY SELF-SERVING.

Exhibit “E-2” (Marked Money)

Comment: Objected for being INADMISSIBLE as evidence being the “Fruit of


the Poisonous Tree”. The accused was illegally arrested and any evidence obtained
in violation of her right shall be inadmissible against her.
Exhibit “F” (Arrest Report)

Comment: Objected to for being PURELY SELF-SERVING.

Exhibit “G” and sub-markings (Photocopy of Barangay Blotters)

Comment: These exhibits and sub-markings are all objected to for being
PURELY SELF-SERVING;

Exhibit “J” and sub-markings (Certificate of Inventory)

Comment: Objected for being INCOMPETENT and INADMISSIBLE as


evidence. During the initial execution of the Certificate of Inventory, the representatives
from the Department of Justice and Media were NOT PRESENT as the said document
was completed only at the Police Station in gross violation of the provisions of RA No.
9165.

Exhibit “K” to “P” (Six (6) Pictures)

Comment: They are objected for being SELF-SERVING and INCOMPETENT


as evidence. The pictures will not prove that accused was legally arrested. It must be
emphasized that admittedly, the same were not taken at the scene of the crime.

Exhibits “Q” to “U” and sub-markings (Five (5) Plastic sachets containing alleged
Marijuana)

Exhibit “V” (Red plastic bag of National Bookstore with marking “CGA”)

Comment: Said six (6) exhibits are Objected for being INADMISSIBLE as
evidence being the “Fruit of the Poisonous Tree”. The accused was illegally arrested
and any evidence obtained in violation of her right shall be inadmissible against her.

WHEREFORE, it is most respectfully prayed of this Honorable Court that the


foregoing Exhibits be DENIED admission.

Other reliefs, just and equitable under the premises are likewise prayed for.

Batangas City, June 28, 2011.

PUBLIC ATTORNEY’S OFFICE


DEPARTMENT OF JUSTICE
BATANGAS DISTRICT OFFICE
PALLOCAN, BATANGAS CITY
Counsel for the Accused

By:

ARSENIO M. HERNANDEZ, JR.


Public Attorney II
IBP Roll No. 49087
IBP Lifetime Member No. 05485
MCLE Compliance No. III-0011319
The Branch Clerk of Court
Regional Trial Court
Branch 7, Batangas City

GREETINGS:

Kindly submit the foregoing Comment / Objection to the Honorable Court


immediately upon receipt.

ARSENIO M. HERNANDEZ, JR.

Copy furnished:
Office of the City Prosecutor
Batangas City