Republic of the Philippines

REGIONAL TRIAL COURT

National Capital Judicial Region
Branch 214
Mandaluyong City

PEOPLE OF THE PHILIPPINES,

Plaintiff,

-versus- Criminal Case No. MC08-12065

For: Murder
BENJAMIN CENTENO
EDGAR CAYANAN and
ARMANDO DEHINO,
Accused,

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

ACCUSED, by the undersigned counsel and unto this Honorable Court,

most respectfully comments and or objects to the Prosecution’s Formal Offer of
Evidence as follows:

Exhibits Purpose

The Accused admits the existence of the Sworn Statements and

Information but denies the due execution thereof.

The Accused questions the regularity of the taking of the four Sworn
“A” Statements as the Investigator fails to justify the necessity of
executing 4 separate Sworn Statements on different dates.

The Accused categorically denies the crime being charged against

him.
“B” Same comment/objection for Exhibit “A”

“C” Same comment/objection for Exhibit “A”

“D” Same comment/objection for Exhibit “A”

The Accused admits the existence of the Spot Report but denies the
due execution thereof.

“E” The Spot Report sources it’s facts from the irregular taking of four
Sworn Statements on different dates. The On-case Erickson T.
Buted failed to show how such taking was done as part of the
standard operating procedure for the investigation of murder cases.
 The Accused admits the existence and due execution of the Birth
“H” Certificate. However, Accused vehemently denies that he should be
held liable for damages for he did not kill the minor’s mother.

The Accused admits the existence and due execution of the Death
Certificate. However, Accused categorically denies that he is the one
“J” who caused the death of Ofelia Salamat.

“J-1” Same comment/objection for Exhibit “J”

To prove that the accused Benjamin Centeno y Cortez was inside

the Metrobank, Libertad Branch prior or the commission of the
crime charged;

To prove the cause of the modus operandi of the accused in their

“K” intended commission of the crime of Robbery;

To prove the accused was in the vicinity of the crime scene at the of
its commission;

To prove that the accused committed the

crime charged.
 To prove the fact of investigation conducted by the police officer
assigned to the case;
“L”
To prove that the standard operating procedure was followed in the
investigation of murder cases.

“L-1” Same purpose as Exhibit “L”

“L-2” Same purpose as Exhibit “L”

“L-3” Same purpose as Exhibit “L”

RESPECTFULLY SUBMITTED.

PRAYER

WHEREFORE, it is most respectfully prayed unto this Honorable Court

that the above-mentioned pieces of evidence be ADMITTED for the purpose for
which they have been offiered.

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

September 12, 2018, City of Mandaluyong.

Office of the City Prosecutor

Halls of Justice, Maysilo Circle,
Mandaluyong City
 RECHELLE REGONDOLA
ND
2 Assistant City Prosecutor

The Clerk of Court

RTC Branch 214
Mandaluyong City

GREETINGS:

Please submit the foregoing Formal Offer Evidence for the consideration
and approval of the Honorable Court immediately upon receipt hereof.

RECHELLE REGONDOLA
2ND Assistant City Prosecutor

Copy furnished:

ATTY. JERIK B. SOLAS

SOLAS LAW OFFICE
Unit 2502, España Tower, Sampaloc, Manila
Counsel for the Accused Benjamin Centeno, Edgar Cayanan and Armando
Dehino