REPUBLIC OF THE PHILIPPINES

MUNICIPAL TRIAL COURT IN CITIES

FOURTH JUDICIAL REGION
Tanauan City, Batangas

THE PEOPLE OF THE

PHILIPPINES,
Plaintiff,
Criminal Case No. 19-019
-versus- For: Acts of Lasciviousness
JOEY SOLIGO y BELACAS
Alias “Bungal”,
Accused.
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OPPOSITION TO PROSECUTION’S
FORMAL OFFER OF EVIDENCE

COMES NOW, accused JOEY SOLIGO y BELACAS, by the

undersigned counsel, to this Honorable Court, most respectfully
objects to the admission of the following exhibits:

Exhibit “A” including its sub-markings — pertaining to the

Sinumpaang Salaysay of April Manzanero.

The above exhibit is objected to on the ground that the

statement given thereon was a fabricated recount of what
transpired on the date material to this case; the same is self-
serving and executed against the accused with ill motives to
justify the false accusation against him. The truth of the matter
is, accused categorically denies the accusation against him.

Exhibits “B”, and “C” — are collectively objected to as

being irrelevant and immaterial to the instant charge against the
accused for acts of lasciviousness;

Exhibits “I”, “J” and “K” (including its sub-markings) —

are collectively objected to as incompetent evidence to prove the
participation of the accused to the alleged crime committed.
Neither the witness hereto has to personal knowledge to the
alleged crime committed. Moreover, exhibit K is further objected
to for alleged execution of checks nor she witness the accused in
the act of signing the subject checks.

PRAYER

WHEREFORE, premises considered, it is most respectfully

prayed that the above exhibits be DENIED as part of the evidence
of the prosecution.
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 Other reliefs just and equitable are likewise prayed for.
24 October 2019, Tanauan City, Batangas, Philippines.

PUBLIC ATTORNEY’S OFFICE

Tanauan City District Office
2/F Dr. Salvador H. Laurel Memorial Building
(Legislative Bldg.)
Lauan St., Brgy. Pob. 3, Tanauan City, Batangas

By:

HEART C. LERO
Public Attorney II
Counsel for the Accused
Roll No. 61581
Lifetime IBP No. 015726
MCLE Compliance No. V-0017604; 04.15.2016

Copy furnished:

Pros. Jocelyn E. Perez-Villagomez

Public Prosecutor
Office of the City Prosecutor

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