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Objections to the Judicial Affidavit of Gabriel Gonzaga:

A18: ​Witness has ​no personal knowledge​ of Shawn’s alleged habitual alcoholism
Q20: Leading question​, presupposes that defendant is in a state or condition during the time of the
incident
A20:​ ​Lacks personal knowledge​, as it was already established that defendant stayed in his car for most
of the time of the incident.
A21: Lacks personal knowledge​ based on the previous ground.
Q27:​ ​Irrelevant.
Q32: Leading.

Objections to the Judicial Affidavit of Maikkie (referred to as Mackie in the JA of


Mark Reyes) Gonzaga:

A13:​ ​Witness has no personal knowledge​, since she heard the loud sound first before going down to
see what had happened.

Objections to the Judicial Affidavit of Angel (referred to as Arnel in his own JA)
Santos:

Personal circumstance states that his name is Angel Santos but referred to as Arnel Santos in his
statements.
A10:​ ​Witness has no personal knowledge​ as to the wife and other neighbors.
A11:​ ​Not responsive and assumes facts not in evidence ​(pertaining to the award)
A15:​ ​Not responsive and assumes facts not in evidence, ​since what was what he felt at the time of
the incident (which is also irrelevant) but answered what the Spouses Gonzaga ​might have​ felt.

Objections to the Judicial Affidavit of Mark Reyes


A14 and A17: ​Inconsistent with the testimony of Gabriel, as he alleged that he stayed in the car and
apologized, implying that he did not argue with defendant
Did not testify as to the alleged barangay conciliation proceedings that happened, despite the fact
that the complaint alleged that he will testify to such fact.
Objections to the Judicial Affidavit of Arnel Santos

A11: It is a narrative answer and the second part is not responsive to the question. ​The witness had
already answered the question with a no, further narration of the witness’ answers is not required.

Q15: What do you feel at that moment?


A15: ​Not responsive to the question​ of the counsel, since he was being asked how HE felt, but he
responded with what he thought what the spouses felt. ​As well as irrelevant​, since Arnel Santos’
emotions have no relevance to the incident.

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