Republic of the Philippines

National Capital Judicial Region

REGIONAL TRIAL COURT
Branch 282, Valenzuela City

PEOPLE OF THE PHILIPPINES

-versus- Criminal Case No. 1259-V-22

For: Qualified theft
MARY ANN OCAÑA SUMAGUE and
JASMINE BESERIL ANSON,
Accused.
x------------------------x

COMMENT ON THE PROSECUTION’S

FORMAL OFFER OF EVIDENCE

The above-named accused, represented by the Public Attorney’s

Office, unto this Honorable Court, most respectfully submit this comment
to the Formal Offer of Exhibits of the prosecution and aver as follows:

Exhibit Comment
A self-serving and biased; neither
B affiant personally saw the accused in
C the act of stealing cash money and
cellphone from the house of Armelito
Trajano Lopez
D to D-3 self-serving and biased; photographs
by themselves do not prove that
Armelito Trajano Lopez truly has a
cash in the amount of P100,000.00
hidden underneath a box in his
cabinet and that either or both
accused forcibly opened the cabinet
and took the said money
E Blotters should not be given undue
significance or probative value for
they are usually incomplete and
inaccurate, sometimes from either
partial suggestions or for want of
suggestions or inquiries. (People v.
Silva, G.R. No. 131591, 29 December
1999)
F self-serving and biased considering
that the videos contained in the USB
flash drive are mere snippets or
excerpts taken from the CCTV

1|Page
 recording; the prosecution did not
submit or made available a copy of
CCTV recordings from 13 April 2022
when the supposed robbery took
place until 16 April 2022 at 10:45 in
the evening when Armelito Trajano
Lopez and his family members
arrived at their house after having a
vacation in Tuguegarao, Cagayan
G self-serving and biased; should not
be given probative value considering
that Arnel Lopez admitted during the
time when he testified that he did
not watch and examine the contents
of the USB flash drive which was
presented in open court;
consequently, he is not in a position
to claim that the videos contained in
the USB flash drive tallies with the
CCTV recordings which were culled
from the CCTV cameras and device
that he owns

PRAYER
WHEREFORE, premises considered, it is most respectfully prayed
that this comment be noted by the Honorable Court.

Other reliefs, just and equitable, are likewise prayed for.

Metro Manila, Valenzuela City, Metro Manila, 15 December 2022.

PUBLIC ATTORNEY’S OFFICE

VALENZUELA DISTRICT OFFICE
st
1 Floor, Metropolitan Trial Court Bldg.
Justice Hall Compound, C.J. Santos St., Poblacion II,
Malinta, Valenzuela City

Through:

ATTY. RAFAEL D. PANGILINAN

Public Attorney II
Roll No. 64684
IBP OR No. 184712 dated 2/17/22 / CALMANA
MCLE Compliance No. VII - 0024379 valid until 4/14/2025

Copy furnished:
SACP Ana Liza C. Dogma

2|Page
Office of the City Prosecutor of Valenzuela City
atty_lizadogma@yahoo.com / ocpvalenzuela.ereceiving@gmail.com

Explanation on the mode of service:

Service of the foregoing comment was made to Office of the City
Prosecutor of Valenzuela City, as well as the Honorable Court through
electronic means in accordance with OCA Circular No. 205-2022 dated 15
August 2022 (Court Operations from 16 August 2022 Until Further Orders
of the Court) which authorizes the filing of pleadings, motions and other
court submissions through electronic mail in areas under Alert Levels 1, 2
or higher.

ATTY. RAFAEL D. PANGILINAN

3|Page