Republic of the Philippines

JUSTICE ON WHEELS
11th Judicial Region
Glan, Sarangani Province
o00o

THE PEOPLE OF THE PHILIPPINES, CRIM. CASE NO. 3242-09

Plaintiff,
- versus - - for -

JOSEPH LAGSILA, VIOLATION OF RA 9165

Accused,
X-------------------X

COMMENT TO THE FORMAL OFFER OF EXHIBIT

ACCUSED, through counsel and unto this Honorable Court, most

respectfully submit his comment and objection to the exhibits offered in evidence
by the prosecution, to wit:

EXHIBIT NATURE COMMENT/OBJECTION

"A" and its Joint Affidavit of POI Nocete -Inconsistent with the testimony in
sub-marking POI Arevalo and PO1 Turtal open court;
- the arrest and search made by the
Police was illegal;

“B” Chemistry Report Admitted as appearing in the

document;

“B-1” and its Chemistry Report Inadmissible in evidence being

Sub-markings (Urinalysis) violative to the right of the accused
Examination conducted was the
effect of illegal arrest;

“C” Chain of Custody Report Inadmissible there being no clear

showing who are the persons who
handled the evidence;

“D” Marijuana Inadmissible being the effect of

Illegal search and seizure.

WHEREFORE, accused respectfully prayed that the exhibits subject of the

objection by the accused be denied admission.

Alabel, Sarangani Province. 01 December 2010.

PUBLIC ATTORNEY'S OFFICE

Department of Justice
Sarangani District Office
Alabel, Sarangani Province
By:

SALVADOR G.TALAMAYAN
District Public Attorney

Copy furnished: PPO by personal service:

“A” Photocopy of P100 bearing Violation of the best evidence rule
SN. CT6808812

“B” Photocopy of P100 bearing Violation of the best evidence rule

SN. WM236258

“C” and its Chemistry Report The specimen submitted is the

sub-markings fruit of poisonous tree;

“D” and its Sketch Admitted to the sketch of the

Sub-markings house only; denied the position
Of the accused and the policemen
Since the same is merely
Fabricated;

"E" and its Joint Affidavit of PO2 Iniba Inconsistent, unbelievable and
sub-marking and PO2 de Guzman contrary to human nature and
experience; the arrest and
search were illegal; objects taken
from the accused were planted
evidence;

“F” and its Police Blotter The police blotter failed to indicate
sub-markings the name of the person subject of
the alleged buy-bust operation; the
blotter failed to indicate the place
of the buy-bust operation;

WHEREFORE, accused respectfully prayed that the exhibits subject of the

objection by the accused be denied admission.

Alabel, Sarangani Province. 05 January 2009.

Page-1

Cont.formal offer..Pp vs. buyoc………..Page-2

RESPECTFULLY SUBMITTED:

PUBLIC ATTORNEY'S OFFICE

Department of Justice
Sarangani District Office
Alabel, Sarangani Province
By:

SALVADOR G.TALAMAYAN
District Public Attorney
Copy furnished: PPO by personal service:

“C” Sachet of shabu The shabu confiscated was the

fruit of poisonous tree;

“D” Plastic Bag Irrelevant and immaterial.

WHEREFORE, accused respectfully prayed that the exhibits subject of the

objection by the accused be denied admission.
 Alabel, Sarangani Province. 23 December 2008.

RESPECTFULLY SUBMITTED:

PUBLIC ATTORNEY'S OFFICE

Department of Justice
Sarangani District Office
Alabel, Sarangani Province
By:

SALVADOR G.TALAMAYAN
District Public Attorney

Copy furnished: PPO by personal service:

sub-markings

“E” Photograph of the marijuana hearsay; not properly identified

“F” Arrest and booking sheet Irrelevant and immaterial since

arrest is illegal;

“G” Gray body bag Irrelevant and immaterial;

“H” Marijuana No intention to possess since the

accused was illegally arrested on
his way to surrender the same.

WHEREFORE, accused respectfully prayed that the exhibits subject of the

objection by the accused be denied admission.

Alabel, Sarangani Province. 14 October 2008.

Page-1

Cont.comment/mangay………………..Page-2
--------------------------------------------------------------------------------------------------

RESPECTFULLY SUBMITTED:

PUBLIC ATTORNEY'S OFFICE

Department of Justice
Sarangani District Office
Alabel, Sarangani Province
By:

SALVADOR G.TALAMAYAN
District Public Attorney
Copy furnished: PPO by personal service:

Page-2

Copy duly served personally:

Provincial Prosecutor's Office

Alabel, Sarangani Province

Date Received:___________
Time Received:___________

Atty. Bonifacio F. Doria, Jr.

Private Prosecutor.
2/F Dinopol Bldg. South Osmeña St.
General Santos City.

EXPLANATION: The foregoing comment was sent to the private prosecutor in his
address mentioned above through registered mail due to lack of manpower and
time constraint.

SALVADOR G.TALAMAYAN