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

4.1. The fact remains unresolved whether or not Dr. Encarnita

Ampil is actually the previous psychiatrist of Complainant which the
Respondent has the burden of proving before the courts of law and
not just by mere allegations;

4.2. Second, the professional opinion remains unverified since no

testimonial evidence or otherwise was submitted by the Respondent
in proving this claim. The fact remains that said professional opinion
remains as an assertion which should not be given any consideration
and at most it can only be considered as hearsay.
4.1. The fact remains unresolved whether or not Dr. Encarnita
Ampil is actually the previous psychiatrist of Complainant which the
Respondent has the burden of proving before the courts of law and
not just by mere allegations;

4.2. Second, the professional opinion remains unverified since no

testimonial evidence or otherwise was submitted by the Respondent
in proving this claim. The fact remains that said professional opinion
remains as an assertion which should not be given any consideration
and at most it can only be considered as hearsay.