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Opposition to Exhibit Offer in Unjust Vexation Case

The document is a comment/opposition filed by the defense lawyer representing Noemi Luis Angela Carranza who is accused of unjust vexation. The defense lawyer opposes the prosecution's formal offer of exhibits "A", "B", and "C" on grounds that they are self-serving and biased. The defense also argues that exhibit "A" lacks proof that it was received by an authorized official of the barangay. The defense lawyer requests the court to note this comment/opposition.

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Raffy Pangilinan
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157 views3 pages

Opposition to Exhibit Offer in Unjust Vexation Case

The document is a comment/opposition filed by the defense lawyer representing Noemi Luis Angela Carranza who is accused of unjust vexation. The defense lawyer opposes the prosecution's formal offer of exhibits "A", "B", and "C" on grounds that they are self-serving and biased. The defense also argues that exhibit "A" lacks proof that it was received by an authorized official of the barangay. The defense lawyer requests the court to note this comment/opposition.

Uploaded by

Raffy Pangilinan
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOC, PDF, TXT or read online on Scribd
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REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION


METROPOLITAN TRIAL COURT
VALENZUELA CITY
BRANCH 82

PEOPLE OF THE PHILIPPINES,

-versus- CRIM. CASE No. 87063


For: Unjust Vexation

NOEMI LUIS ANGELA


CARRANZA,
Accused.
x- - - - - - - - - - - - - - - - - - - - - - - -x

COMMENT/OPPOSITION TO THE
PROSECUTION’s FORMAL OFFER OF EXHIBITS
COMES NOW, accused NOEMI LUIS ANGELA CARRANZA,
represented by the Public Attorney’s Office, unto this Honorable Court, by
way of comment/opposition to the prosecution’s formal offer of exhibits,
most respectfully avers as follows:

Exhibit No. Description Comment/Opposition


“A” with Authorization There is no proof that a copy of the notice of
sub-marking dated April 2, authorization was in truth received by an
2015 issued authorized official or employee of Barangay
by to Edward Bignay as the person who signed who
C. Garcia and purportedly signed the same was not called
Ricardo to the witness stand to affirm that she
Gequilasao actually received said copy, to identify her
signature, and to prove that she is actually an
official or employee of Barangay Bignay and
is authorized to acknowledge receipt of
documents for and in behalf of the barangay.
Even if it be conceded that the signatory is so
authorized, there is no proof that a copy of
the notice of authorization was circulated to
the members of the homeowner’s association
of Valenzuela Ville Subdivision.
“B” with Salaysay of The defense objects to its admission for
sub-marking Ricardo F. being self-serving and biased.
Gequilasao
“C” with Joint-Reply The defense also objects to its admission for

1
sub-marking Affidavit being self-serving and biased.
executed by
Edward
Garcia and
Ricardo F.
Gequilasao
dated June 5,
2015

PRAYER

WHEREFORE, premises considered, it is respectfully prayed unto


this Honorable Court that the instant Comment/Opposition be NOTED.

Other reliefs and remedies, just and equitable, are likewise prayed for.

Valenzuela City, Metro Manila, 25 November 2016.

PUBLIC ATTORNEY’S OFFICE


VALENZUELA DISTRICT OFFICE
3RD Floor, Post Office Bldg.
Justice Hall Compound,
Malinta, Valenzuela City

Through:

ATTY. RAFAEL D. PANGILINAN


Public Attorney I
Roll No. 64684
IBP No. 1012177
Admitted to the Bar on April 29, 2015
MCLE Compliance V – 0011951 dated Nov. 11, 2015

Notice of Hearing:
Mrs. Helen M. Evangelista
Clerk of Court III
Metropolitan Trial Court – Branch 82
Valenzuela City

Greetings! Please take notice that the undersigned will submit the
foregoing Comment/Opposition for the Honorable Court’s consideration
immediately upon receipt hereof.

2
ATTY. RAFAEL D. PANGILINAN

Copy furnished:
SACP Randy C. Caingal
Office of the City Prosecutor
Valenzuela City

Atty. Ernesto F. Urbano


Counsel for the Complainant
URBANO, PALAMOS & FABROS
Suite 1510 Future Point Plaza I
112 Panay Avenue, Quezon City

Explanation:
Service of the foregoing Comment/Opposition upon Atty. Ernesto F.
Urbano was made through registered mail for lack of personnel to effect
personal service.

ATTY. RAFAEL D. PANGILINAN

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