REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

METROPOLITAN TRIAL COURT
BRANCH 14, MANILA

PEOPLE OF THE PHILIPPINES,

Plaintiff,

- versus - Crim. Case: 318730-SA

MARIANO TAGANGUIN y CARANGUIAN,

Accused.
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COMMENTS AND OBJECTIONS

TO PROSECUTION’S FORMAL OFFER OF EVIDENCE

Accused MARIANO TAGANGUIN, through the undersigned

counsel and unto this Honorable Court, most respectfully submits the
following Comments and/or Objections to the Prosecution’s Formal Offer
of Evidence, to wit:

1. Exhibits “A-1” (The signature of Inquest Prosecutor Elseray

Noro), “E” (Receipt No. 3615 dated September 4, 1999), “F”
(Receipt No. 3613 dated September 3, 1999), “G” (Receipt No.
2248 dated August 26, 1999), “H” (Receipt No. 2226 dated
August 26, 1999), “I” (Voucher from Tres Amigos Memorial
Chapel), “J” (Medical Certificate from United Doctors Medical
Center dated August 16, 2001, “L” (Consultation form of
UDMC’s Department of Emergency Medicine, “O” (Sketches of
Edwin Cervantes’ body), and “P” (Additional sketches of Edwin
Cervantes’ body), and their respective submarkings are objected
to for being HEARSAY, as they were not properly identified
considering that the respective persons who have personal
knowledge on them, having allegedly executed, issued or
otherwise certified the same, failed to appear before the
Honorable Court to testify on the existence and genuineness
thereof.
 2. Exhibits “B” (The Booking Sheet and Arrest Report dated
August 20, 1999), “D” (Marriage Certificate of Edwin Cervantes
and Rosalinda Cervantes) “K” (Medical Examination Report
from UDMC), and “Q” (Death Certificate of Edwin Cervantes),
and their respective submarkings are objected to for being
VIOLATIVE OF THE BEST EVIDENCE RULE, copies of the
same attached to the records of the case being mere
photocopies, the alleged original copies thereof not properly
introduced and identified in Court).

WHEREFORE, all told, accused through counsel respectfully

moves that the foregoing comments and objections be duly noted and
considered by the Honorable Court.

All other just and equitable reliefs are likewise prayed for.

Manila, 11 March 2005

Department of Justice
PUBLIC ATTORNEY’S OFFICE
Manila District Office
4th Floor Godino Building
350 A. Villegas St., Arroceros, Manila

By:

MICHELLE ANN A. TOLEDO

Public Attorney

Copy Furnished:

ACP GLENDA ECHALAR-LUCERES

Office of the City Prosecutor
Manila City Hall