ASSIGNMENT OF ERRORS

A. THE OFFICE OF THE CITY PROSECUTOR ERRED IN

FAILING TO FIND PROBABLE CAUSE FOR THE
COMPLAINT FOR KIDNAPPING AND SERIOUS ILLEGAL
DETENTION

GROUNDS TO SUPPORT THE APPEAL

PROOF OF SERVICE

1. how the children truly believed the need for complainant to be

given immediate psychiatric intervention;

3.1. It must be noted that Respondent’s arguments are defenses

evidentiary in nature which much be threshed-out in a full-blown
trial;

3.2. The issue remains whether or not the children of the

complainant actually spoke to the Respondent Ponio. Complainant
strongly clutches to the incident that the first time that she saw the
Respondent, Respondent’s first remarks were “Who are you and why
are you here?”. This fact strongly negates the assertion of the
respondent that she actually spoke to the children of the complainant,
much more negates the assertion that the children truly believed the
need for complainant to be given immediate psychiatric intervention.