Republic of the Philippines

National Capital Judicial Region

METROPOLITAN TRIAL COURT
Branch 66
Makati City

PEOPLE OF THE PHILIPPINES,

Complainant,

-versus- CRIMINAL CASE NO.

16-04118

MARY GRACE GARCIA,

Accused.

x------------------------------------ x
OBJECTIONS TO THE PROSECUTION’S FORMAL OFFER OF
EVIDENCE DATED MARCH 7, 2019

Accused MARY GRACE GARCIA, through her counsel the

CENTRO ESCOLAR UNIVESITY, SCHOOL OF LAW AND
JURISPRUDENCE – OFFICE OF THE LEGAL AID, most respectfully
submit the foregoing:

EXHIBIT and COMMENTS/OBJECTIONS

DESCRIPTION

Exhibit A – Complaint-Affidavit The complaint-affidavit of the Gina

of the Gina Noynay and Epifaño Noynay and Epifaño Septimo
Septimo dated May 17, 2016 contained allegations that the
accused uttered grave threats.

However, the present criminal

case only pertains to the
purported oral defamation
committed by the accused. It does
not refer anything to the crime of
Grave Threats under Article 282 of
the Revised Penal Code.

In fact, in the Prosecutor’s

Resolution dated August 4, 2016,
it found that there is no valid and
legal basis to charge the accused
with the crime of Grave Threats. It

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 was even found that the purported
crime had already prescribed.

Thus, the allegations in the

Complaint-Affidavit regarding the
purported acts constituting as
Grave Threats should be
inadmissible and stricken out of
the records as they have no
relevance to the present criminal
proceedings.

WHEREFORE, it is respectfully prayed that this Honorable

Court consider the above-stated Objections to the Prosecution’s
Formal Offer of Evidence. Other just and equitable reliefs are
likewise prayed for.

City of Makati, September 17, 2019.

CENTRO ESCOLAR UNIVERSTY

SCHOOL OF LAW AND JURISPRIDENCE
OFFICE OF THE LEGAL AID
259 Sen. Gil Puyat Avenue, Makati City
(+63)2 843-0300 loc. 102

_____________________________
Supervising Lawyer
Roll No. ________
PTR No. _________ | _________, 2019 | _________
IBP No. ___________ | __________, 2019 | _________
MCLE Compliance No. ___________ | ___________

_______________
Senior Legal Intern of the CEU – OLA

_______________
Senior Legal Intern of the CEU – OLA

_______________
Senior Legal Intern of the CEU – OLA

_______________
Senior Legal Intern of the CEU – OLA
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Copy furnished:

ATTY. DIOMER L. PRIELA

Counsel for the Complainant
Assistant City Prosecutor
Office of the City Prosecutor
16th Flr., New Makati City Hall Bldg.
J.P. Rizal St., Makati City

EXPLANATION

Service on the adverse party cannot be done personally as

the CEU - OLA at present does not have a permanent messenger
and therefore has no adequate manpower to serve pleadings
personally. The temporary messenger still has to file pleadings in
cases of equal importance.

(Supervising Lawyer)

NOTICE OF HEARING

Branch Clerk of Court

Metropolitan Trial Court
Branch 66
Makati City

Greetings: Please take notice that the foregoing Omnibus

Motion shall be submitted for the consideration of the Honorable
Court on ________ at ________ (a.m./p.m.) or as soon as counsel
and matter may be heard.

(Supervising Lawyer)

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