REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
VALENZUELA CITY
Branch 171

PEOPLE OF THE PHILIPPINES,

Plaintiff,

vs. Crim. Case No. 2232-V-17

MABEL ALEJANDRO y CARAS, ET. AL.,

Accused,
X-----------------------------------------------------------X
PEOPLE OF THE PHILIPPINES,
Plaintiff,

vs. Crim. Case No. 2233-V-17

MABEL ALEJANDRO y CARAS, ET. AL.,

Accused,
X-------------------------------------------------------------X

COMMENT/OBJECTIONS
(To the Prosecution’s Formal Offer of Object and Documentary Evidence)

ACCUSED by the undersigned counsel and unto this Honorable Court, most
respectfully comments and/or objects to the admission of the Prosecution’s Formal Offer
of Object Evidence as follows:

The ACCUSED further objects to the purpose of the offer as follows:

EXHIBITS DESCRIPTION COMMENTS/OBJECTIONS

“A” Complaint Sheet of Mischelle
Mateo dated August 7, 2017
The Accused objects to the purpose of the
offer specifically which is to attest to the
incident pertaining to the commission of the
crime of Robbery and Carnapping by accused
Alejandro, Fabro and Tengay.

It has been declared in open court and that the

records would attest that the witness failed to
identify the three accused and specifically
narrate their participation to the crime charged.
Thus, the testimony of the witness with regard
to this matter would all be IRRELEVANT,
HEARSAY, PURELY SELF-SERVING, AND
THUS INADMISSIBLE AS EVIDENCE. At
cross, she categorically admitted that she did
not see the accused perpetrating the crime,
thus, her assumption that the three accused
participated in the crime charged is mere

Page 1 of 6
 speculation inadmissible in evidence.

“B” Complaint Sheet of Jonalyn The Accused objects to the purpose of the
Dalusung dated August 7, offer specifically which is to establish the
2017 presence of the accused at the scene of the
crime.

The complaint sheet of Jonalyn Dalusung is

inadmissible in evidence for being
IRRELEVANT, HEARSAY & PURELY SELF-
SERVING. Ms. Dalusung is incompetent to
testify to establish the presence of the
accused at the scene of the crime during its
actual commission. SHE HAS NO
PERSONAL KNOWLEDGE NOR HAS A
WELL-GROUNDED BELIEF THAT THE
ACCUSED WERE AT THE SCENE OF THE
CRIME FOR THE OBVIOUS REASON THAT
SHE WAS NOT PRESENT AT THE TIME THE
ALLEGED CRIME WAS COMMITTED.

The Accused also objects to the purpose of

the offer which is to establish the
circumstances surrounding the commission of
the crime. The witness herself admitted that
she was not there in Valenzuela. She did not
see the alleged facts since she arrived only
when the alleged crime had already been
committed negated actual knowledge on the
circumstances surrounding the commission of
the crime, thus, there was no way for Ms.
Dalusung to exactly establish the facts on the
actual commission of the crime. Whatever she
may conclude from the things she had
collected are pure speculations inadmissible in
evidence.

“C Complaint Sheet of Angelina The Accused objects to the purpose of the

Dalusung offer specifically which is to establish the
presence of the accused at the scene of the
crime.

The complaint sheet of Angelina Dalusung is

inadmissible since she was not presented as
one of the witnesses for the prosecution. The
said document is also inadmissible for being
IRRELEVANT, HEARSAY & PURELY SELF-
SERVING. Ms. Dalusung is incompetent to
testify to establish the presence of the
accused at the scene of the crime during its
actual commission. SHE HAS NO
PERSONAL KNOWLEDGE NOR HAS A
WELL-GROUNDED BELIEF THAT THE
ACCUSED WERE AT THE SCENE OF THE
CRIME FOR THE OBVIOUS REASON THAT

Page 2 of 6

D Salaysay of Mischelle Mateo &
Karagdagang Salaysay
F Salaysay of Jhazelle Hueyd
Alamin
Page 3 of 6
SHE WAS NOT PRESENT AT THE TIME THE
ALLEGED CRIME WAS COMMITTED.
Whatever she may conclude from the things
she had collected are pure speculations
inadmissible in evidence.
.
The Accused objects to the purpose of the
offer specifically which is to attest to the
incident pertaining to the commission of the
crime of Robbery and Carnapping by accused
Alejandro, Fabro and Tengay.
It has been declared in open court and that the
records would attest that the witness failed to
identify the three accused and specifically
narrate their participation to the crime charged.
Thus, the testimony of the witness with regard
to this matter would all be IRRELEVANT,
HEARSAY, PURELY SELF-SERVING, AND
THUS INADMISSIBLE AS EVIDENCE. At
cross, she categorically admitted that she did
not see the accused perpetrating the crime,
thus, her assumption that the three accused
participated in the crime charged is mere
speculation inadmissible in evidence.
The Accused objects to the purpose of the
offer specifically which is to establish the
presence of the accused at the scene of the
crime.
The complaint sheet of Angelina Dalusung is
inadmissible since she was not presented as
one of the witnesses for the prosecution. The
said document is also inadmissible for being
IRRELEVANT, HEARSAY & PURELY SELF-
SERVING. Ms. Dalusung is incompetent to
testify to establish the presence of the
accused at the scene of the crime during its
actual commission. SHE HAS NO
PERSONAL KNOWLEDGE NOR HAS A
WELL-GROUNDED BELIEF THAT THE
ACCUSED WERE AT THE SCENE OF THE
CRIME FOR THE OBVIOUS REASON THAT
SHE WAS NOT PRESENT AT THE TIME THE
ALLEGED CRIME WAS COMMITTED.
Whatever she may conclude from the things
she had collected are pure speculations
inadmissible in evidence.
 Salaysay of John Lervie The Accused objects to the purpose of the
G Alamin offer specifically which is to attest to the
incident pertaining to the commission of the
crime of Robbery and Carnapping by accused
Alejandro, Fabro and Tengay.

It has been declared in open court and that the

records would attest that the witness failed to
identify the three accused and specifically
narrate their participation to the crime charged.
Thus, the testimony of the witness with regard
to this matter would all be IRRELEVANT,
HEARSAY, PURELY SELF-SERVING, AND
THUS INADMISSIBLE AS EVIDENCE. At
cross, she categorically admitted that she did
not see the accused perpetrating the crime,
thus, her assumption that the three accused
participated in the crime charged is mere
speculation inadmissible in evidence.

H Salaysay of Jonalyn Dalusung The Accused objects to the purpose of the

offer specifically which is to establish the
presence of the accused at the scene of the
crime.

The complaint sheet of Jonalyn Dalusung is

inadmissible in evidence for being
IRRELEVANT, HEARSAY & PURELY SELF-
SERVING. Ms. Dalusung is incompetent to
testify to establish the presence of the
accused at the scene of the crime during its
actual commission. SHE HAS NO
PERSONAL KNOWLEDGE NOR HAS A
WELL-GROUNDED BELIEF THAT THE
ACCUSED WERE AT THE SCENE OF THE
CRIME FOR THE OBVIOUS REASON THAT
SHE WAS NOT PRESENT AT THE TIME THE
ALLEGED CRIME WAS COMMITTED.

The Accused also objects to the purpose of

the offer which is to establish the
circumstances surrounding the commission of
the crime. The witness herself admitted that
she was not there in Valenzuela. She did not
see the alleged facts since she arrived only
when the alleged crime had already been
committed negated actual knowledge on the
circumstances surrounding the commission of
the crime, thus, there was no way for Ms.
Dalusung to exactly establish the facts on the
actual commission of the crime. Whatever she
may conclude from the things she had
collected are pure speculations inadmissible in
evidence.

Page 4 of 6

I Salaysay ng Pagtestigo of
Howard Banaag
J Salaysay ng Pagtestigo of
Melanie Avila
K Letter of Dir. Archie Grande
dated August 18, 2017
LM Photocopy of OR and CR
Page 5 of 6
The Accused objects to the purpose of the
offer specifically which is to attest to the
incident pertaining to the commission of the
crime of Carnapping by accused Alejandro,
Fabro and Tengay.
It has been declared in open court and that the
records would attest that the witness failed to
narrate if indeed there was crime committed.
He also failed to identify the three accused
and specifically narrate their participation to
the crime charged. Thus, the testimony of the
witness with regard to this matter would all be
IRRELEVANT, HEARSAY, PURELY SELF-
SERVING, AND THUS INADMISSIBLE AS
EVIDENCE. At cross, he categorically
admitted that he did not see the accused
perpetrating the crime, thus, his assumption
that the three accused participated in the
crime charged is mere speculation
inadmissible in evidence.
The document is inadmissible since she was
not presented as one of the witnesses for the
prosecution. The said document is also
inadmissible for being IRRELEVANT,
HEARSAY & PURELY SELF-SERVING. Ms.
Avila is incompetent to testify to establish the
presence of the accused at the scene of the
crime during its actual commission. SHE HAS
NO PERSONAL KNOWLEDGE NOR HAS A
WELL-GROUNDED BELIEF THAT THE
ACCUSED WERE AT THE SCENE OF THE
CRIME FOR THE OBVIOUS REASON THAT
SHE WAS NOT PRESENT AT THE TIME THE
ALLEGED CRIME WAS COMMITTED.
Whatever she may conclude from the things
she had collected are pure speculations
inadmissible in evidence
The document is inadmissible for being
HEARSAY since the author was not presented
as one of the witnesses for the prosecution.
The said document is also inadmissible for
being IRRELEVANT.
The document is inadmissible for being
violative of the BEST EVIDENCE RULE. The
prosecution failed to establish the admissibility
of Secondary Evidence. The said document is
also inadmissible for being IRRELEVANT.
NOPQ Investigation Data Form from
Laguna Prosec Office, Referral
for Inquest dated 8/7/17,
Request for Digital Forensic
Examination
IRRELEVANT & SELF SERVING in so far as
Accused Alejandro, Tengay and Fabro are
concerned.

RTUW Certificate of Live Birth of
Jonalyn Dalusung, ,
Documents relative to CC
NBo. 30215-17 for Robbery
with violence before RTC
Calamba.
Inadmissible since the documents were not
identified by any of the witnesses.
Also IRRELEVANT & SELF SERVING in so
far as Accused Alejandro, Tengay and Fabro
are concerned.

S,T, U & Investigation Data Form from No objection to its admissibility.

Series Office of the City Prosecutor of
Meycauayan Bulacan, Chain of
Custody Form, Documents
relative to CC No. 4444-M-
2017, pending before RTC
Malolos Bulacan

V to V-6 Receipts/Documents The Accused objects to the purpose of the

pertaining to the jewelries offer specifically which is to corroborate the
testimony of the first witness based on this
receipts.

These receipts are IRRELEVANT & SELF

SERVING since its contents do not
corresponds to the amount and other details of
those items allegedly lost as contained in the
Information.

RELIEF

WHEREFORE, Accused most respectfully prays to this Honorable Court that the
foregoing object and documentary exhibits mentioned above be denied admission for
the reasons above stated. The Accused further prays for such other relief as may be
just and equitable under the premises.

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