COMMENT TO FORMAL OFFER P Vs Dionesio

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REPUBLIC OF THE PHILIPPINES


National Capital Judicial Region
REGIONAL TRIAL COURT
Branch 194, Parañaque City

PEOPLE OF THE PHILIPPINES,


Plaintiff,

versus
CRIMINAL CASE NO. 2019-0106
FOR: VIOLATION OF SEC. 5(i) RA 9262
KENNETH DIONESIO,
Accused.
x------------------------------------------x

COMMENT TO THE FORMAL OFFER OF EVIDENCE


BY THE DEFENSE

The private complainant, through the undersigned counsel, by


way of comment to the Formal Offer of the accused’s evidence,
respectfully alleges and OBJECTS to the following:

EXHIBIT NATURE REASON


The purpose of this
evidence does not
Bank Statement of prove actual support
3 Account for January by the accused for his
2015 and the private
complainant’s
daughter.
The document only
proves ownership of
the motorcycle, and
4 Motorcycle Records
not actual use of the
same for the family’s
benefit.
Receipts dated 22 These documents
5-5G May 2019 until 6 only prove
February 2020 “support”given for this
period, not covering
the time when the
Receipts of School
6-6B parties separated
Supplies
from each other last
28 September 2016.
7 Medico-legal Report The purpose for
dated 17 January which this evidence is
2020 offered is immaterial
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to the charges
against the accused.

PRAYER

WHEREFORE, premises considered, the private complainant


respectfully prays that the above objections be considered by this
Honorable Court, and therefore deny the admission of the above
documents for the purposes they are offered.

The private complainant likewise prays for such other reliefs as


may be deemed just and equitable under the premises.

Parañaque City, 7 September 2020.

JOSEPH JOHN GERALD M. AGUAS


Counsel for the private complainant
#28 Rafael Gonzales Street, Sinagtala Subdivision
BF Homes, Parañaque City 1720
PTR No. 1055254, Lucena City, 7 January 2020
Roll of Attorneys No. 38313
IBP Lifetime No. 425593 23 December 1996
MCLE Compliance No. VI-8203, valid until 14 April 2022
[email protected]

Copy furnished:

OFFICE OF THE CITY PROSECUTOR


Parañaque City

ATTY. GE ANN FRANCIA S. ROSALES


Counsel for the Accused
71 Buencamino Street
BF Homes, Parañaque City 1720
Registry Receipt No. _________

Copies of the foregoing pleading were sent to the other parties by


registered mail due to the time, distance and lack of manpower
needed to make personal delivery unavailable.

JOSEPH JOHN GERALD M. AGUAS

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