Republic of the Philippines

REGIONAL TRIAL COURT

Third Judicial Region
City of Malolos, Bulacan
BRANCH 6

PEOPLE OF THE PHILIPPINES,

-versus- Crim. Case No. 3042-M-2016

RAMON MATURINGAN y MARTIN,

Accused.
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PEOPLE OF THE PHILIPPINES,

-versus- Crim. Case No. 3043-M-2016

RAMON MATURINGAN y MARTIN,

Accused.
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PEOPLE OF THE PHILIPPINES,

-versus- Crim. Case No. 3044-M-2016

RAMON MATURINGAN y MARTIN,

Accused.
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PEOPLE OF THE PHILIPPINES,

-versus- Crim. Case No. 3045-M-2016

ABEGLENN DOMINGO y MERCADO,

Accused.
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DEMURRER TO EVIDENCE
 2

Accused, RAMON MATURINGAN y MARTIN and ABEGLENN

DOMINGO y MERCADO, by counsel, to this Honorable Court, most
respectfully submit their Demurrer to Evidence and AVER:

BASIS FOR THE DEMURRER

At the onset of every prosecution is the protection accorded by the

Constitution to the presumption of innocence in favor of an accused. Thus,
People vs. Garcia1 emphasized:

“Every criminal case starts with the constitutionally-protected

presumption of innocence in favor of the accused that can only be defeated by
proof beyond reasonable doubt. The prosecution starts the trial process by
presenting evidence showing the presence of all the elements of the offense
charged. If the prosecution proves all the required elements, the burden of
evidence shifts to the accused to disprove the prosecutions case. Based on these
presentations, the court must then determine if the guilt of the accused has been
proven beyond reasonable doubt. It may happen though that the prosecution,
even before the presentation by the defense, already has failed to prove all the
elements of the crime charged, in which case, the presumption of innocence
prevails; the burden of evidence does not shift to the accused, who no longer
needs to present evidence in his defense.”

Where the evidence for the prosecution fails to establish even the
commission of the crime and the existence of the elements thereof, the accused
may demur from the evidence presented, as provided under Section 23, Rule
119 of the Revised Rules of Criminal Procedure, thus:

“Sec. 23. After the prosecution rests its case, the court may dismiss the
action on the ground of insufficiency of evidence (1) on its own initiative after
giving the prosecution the opportunity to be heard or (2) upon demurrer to
evidence filed by the accused with or without leave of court.

x x x”

In the instant case, the prosecution failed to establish that the elements
constituting violation of Sections 5 and 11, Article II of R.A. 9165
(Comprehensive Dangerous Drugs Act of 2002” exist. Thus, this demurrer to
evidence.

ARGUMENTS/DISCUSSION

Accused was charged under Informations for Violation of Sec. 5 and 11

Art. II of R. A. 9165, otherwise known as the comprehensive dangerous drugs
act of 2002, as follows:

(Copy informations)

Testimonies full of
1
G.R. No. 173480, February 25, 2009.
 3

Inconsistencies that render

the operation suspect

During the trial of the case, the prosecution was able to present four (4)
witnesses, namely:

1) Police Major Gina Manangquil Camposano, whose testimony was

stipulated upon being the forensic chemist who conducted the
examination of the drug specimen submitted to her and found them
positively containing illegal drugs but who had no personal knowledge as
to the source and origin of the specimen, how they were confiscated and
the manner of the arrest of the accused;
2) PSSG Marlon Mito, whose testimony was stipulated upon being merely
the back up officer who did not handle any of the drug evidence and who
will testify in the manner as stated in his Sinumpaang Salaysay;
3) PCPL Marcelo Pardo, whose testimony was stipulated upon being the
investigator on case who will testify in the manner as stated in his
Affidavit, since he has no personal knowledge of the source of the
specimen, the manner of the arrest of the accused and the manner of the
seizure of the seized items;
4) Pat. Jaypee Fajardo who testified in open court, being the prosecution’s
material witness in view of his role in the operation as poseur buyer.

The testimony of Pat. Fajardo as to the conduct of the operation, from the
time the information was relayed by a confidential asset, to the alleged
surveillance and the actual buy-bust operation had been littered with
loopholes and inconsistencies, that rendered the operation suspect. The
alleged buy-bust operation was conducted with the aid of a confidential
asset, whose knowledge about drug personalities was, according to the
witness, merely on account of the asset’s being “tsimoso”.

The purported poseur buyer’s narrative of the actual buy-bust operation

itself does not inspire belief. His declarations are tentative, at best, and at
worst, incredulous. The lack of a prior communication with the target is
obvious in the fact that the team allegedly had to wait for three hours for
the target to arrive. It is also unbelievable that the target would just be
walking freely to the place where the buy-bust allegedly took place, since
there was, in implementation, a community lockdown curfew. The
incredulity of the operation is exposed by the inconsistences in the
declarations of the Officer Fajardo, from the time the information was
relayed by an informant to the alleged surveillance to the actual buy-bust
and more obtrusively, as to the links in the chain of custody of the drug
specimen allegedly seized from the accused. In People of the Philippines
vs. Hilario, et al., the Supreme Court emphasized the importance of
narrating the specific details on the planning and conduct of buy-bust
operations:
“The lack of specific details on the planning and conduct of the buy-bust operation on January 22, 2008 in Brgy.
Maguihan casts serious doubts that it actually took place and/or that the police officers carried out the same in
the regular performance of their official duties. Relevant herein is the following discourse of the Court on buy-
bust operations in People v. Ong[26]:
 4

A buy-bust operation is a form of entrapment, which in recent years has been accepted as a valid means of
arresting violators of the Dangerous Drugs Law. It is commonly employed by police officers as an effective way
of apprehending law offenders in the act of committing a crime. In a buy-bust operation, the idea to commit a
crime originates from the offender, without anybody inducing or prodding him to commit the offense. Its opposite
is instigation or inducement, wherein the police or its agent lures the accused into committing the offense in order
to prosecute him. Instigation is deemed contrary to public policy and considered an absolutory cause.

To determine whether there was a valid entrapment or whether proper procedures were undertaken in
effecting the buy-bust operation, it is incumbent upon the courts to make sure that the details of the
operation are clearly and adequately laid out through relevant, material and competent evidence. For, the
courts could not merely rely on but must apply with studied restraint the presumption of regularity in the
performance of official duty by law enforcement agents. This presumption should not by itself prevail
over the presumption of innocence and the constitutionally protected rights of the individual. It is the duty
of courts to preserve the purity of their own temple from the prostitution of the criminal law through lawless
enforcement. Courts should not allow themselves to be used as instruments of abuse and injustice lest innocent
persons are made to suffer the unusually severe penalties for drug offenses.
In People v. Doria, we stressed the "objective" test in buy-bust operations. We ruled that in such
operations, the prosecution must present a  complete picture detailing the transaction, which "must start
from the initial contact between the poseur-buyer and the pusher, the offer to purchase, the promise or
payment of the consideration until the consummation of the sale by the delivery of the illegal drug
subject of the sale. We emphasized that the manner by which the initial contact was made, the offer to
purchase the drug, the payment of the 'buy-bust' money, and the delivery of the illegal drug must be the
subject of strict scrutiny by courts to insure  that law-abiding citizens are not unlawfully induced to
commit an offense."
In the case at bar, the prosecution evidence about the buy-bust operation is incomplete.  The confidential
informant who had sole knowledge of how the alleged illegal sale of shabu started and how it was perfected was
not presented as a witness. His testimony was given instead by SPO1 Gonzales who had no personal
knowledge of the same. On this score, SPO1 Gonzales' testimony is hearsay and possesses no probative value
unless it can be shown that the same falls within the exception to the hearsay rule. To impart probative value to
these hearsay statements and convict the appellant solely on this basis would be to render nugatory his
constitutional right to confront the witness  against him, in this case the informant, and to examine him for his
truthfulness. As the prosecution failed to prove all the material details of the buy-bust operation, its claim that
there was a valid entrapment of the appellants must fail. (Emphases supplied, citations omitted.)”

While jurisprudence is settled that inconsistencies in the testimonies of

prosecution witnesses with respect to minor details and collateral matters do not affect
the substance of their declaration nor the veracity or weight of their testimony, 2 the
inconsistencies in the instant case deal with the corpus delicti – the dangerous drugs
themselves. Hilario, supra, is instructive:

“In cases of illegal sale and illegal possession of dangerous drugs, the dangerous drug seized from the accused
constitutes the corpus delicti of the offense. Thus, it is of utmost importance that the integrity and identity of the
seized drugs must be shown to have been duly preserved. "The chain of custody rule performs this function as it
ensures that unnecessary doubts concerning the identity of the evidence are removed."”

The testimony of Officer Fajardo failed dismally to establish the corpus

delicti, as he was unable to show that the integrity and identity of the
seized drugs have been duly preserved. His testimony vis-à-vis that of
the others on record reveals quite the opposite.

Chain of custody of seized drugs

Not established.

In People of the Philippines v. Lim,3 the Supreme Court, en banc,

elucidated on the purpose, object and nature of the chain of custody rule:

2
Calma vs. People of the Philippines, G.R. No. 180586, November 20, 2017.

3
G.R. No. 231989, September 04, 2018.
 5

“The chain of custody rule is but a variation of the

principle that real evidence must be authenticated prior to its
admission into evidence. 12 To establish a chain of custody
sufficient to make evidence admissible, the proponent needs
only to prove a rational basis from which to conclude that
the evidence is what the party claims it to be. 13 In other
words, in a criminal case, the prosecution must offer
sufficient evidence from which the trier of fact could
reasonably believe that an item still is what the government
claims it to be. 14 Specifically in the prosecution of illegal
drugs, the wellestablished federal evidentiary rule in the
United States is that when the evidence is not readily
identifiable and is susceptible to alteration by tampering or
contamination, courts require a more stringent foundation
entailing a chain of custody of the item with sufficient
completeness to render it improbable that the original item
has either been exchanged with another or been
contaminated or tampered with. 15 This was adopted in
Mallillin v. People, 16 where this Court also discussed how,
ideally, the chain of custody of seized items should be
established:

As a method of authenticating evidence, the chain of

custody rule requires that the admission of an exhibit be
preceded by evidence sufficient to support a finding that the
matter in question is what the proponent claims it to be. It
would include testimony about every link in the chain, from
the moment the item was picked up to the time it is offered
into evidence, in such a way that every person who touched
the exhibit would describe how and from whom it was
received, where it was and what happened to it while in the
witness' possession, the condition in which it was received
and the condition in which it was delivered to the next link in
the chain. These witnesses would then describe the
precautions taken to ensure that there had been no change in
the condition of the item and no opportunity for someone not
in the chain to have possession of the same.

Thus, the links in the chain of custody that must be

established are: (1) the seizure and marking, if practicable,
of the illegal drug recovered from the accused by the
apprehending officer; (2) the turnover of the seized illegal
drug by the apprehending officer to the investigating officer;
(3) the turnover of the illegal drug by the investigating
officer to the forensic chemist for laboratory examination;
and (4) the turnover and submission of the illegal drug from
the forensic chemist to the court.”
 6

Thus, where the subject of inquiry is an operation involving the sale

and/or possession of illegal drugs, the chain of custody goes to the very heart of
corpus delicti, and all the links in the chain must be established in order to
prove the identity of the drug, beyond reasonable doubt.

The First Link

What constitutes the first link is described quite succinctly in People vs.
Villar:4

“The first stage in the chain of custody is the marking

of the dangerous drugs or related items. Marking, which is
the affixing on the dangerous drugs or related items by the
apprehending officer or the poseur-buyer of his initials or
signature or other identifying signs, should be made in the
presence of the apprehended violator immediately upon
arrest. The importance of the prompt marking cannot be
denied because succeeding handlers of the dangerous drugs
or related items will use the marking as reference. Also, the
marking operates to set apart as evidence the dangerous
drugs or related items from other material from the moment
they are confiscated until they are disposed of at the close of
the criminal proceedings, thereby forestalling switching,
planting, I or contamination of evidence. In short, the
marking immediately upon confiscation or recovery of the
dangerous drugs or related items is indispensable in the
preservation of their integrity and evidentiary value.”

In this case, the arresting officer who allegedly seized the drugs admitted
that the marking of the evidence was not done immediately upon arrest of
the accused. Police Officer Fajardo declared in his direct examination:

“Fiscal Ellen Lucas-Hausam

Q: And what happened? Were you able to arrest Kenneth?

A: Yes, mam.

Q: After arresting him, what happened?

A: We informed him of his constitutional rights, ma’am.

Q: Other than that, what did you do next, if any?

A: We brought him to the police station.

Q: Before you brought him to the police stteion, what did you do
to him if any?
A: We conducted the inventory of the seized items, ma’am.

Q: What were those seized items that you are referring to?
4
G.R. No. 215937, 9 November 2016.
 7

A: Illegal drugs, ma’am.

Q: Illegal drugs, how many illegal drugs, if any?

A: We were able to recover four (4) ma’am, aye three (3)
ma’am.

COURT TO WITNESS
Q: Four or three?
A: Four (4), Your Honor.

From his direct testimony, it appears that the marking was not done
immediately after its confiscation. This was affirmed by the witness
during his cross-examination:

ATTY. CRUZ:
Q: Mr. Witness, you also stated that you were the one, you were
the only one, who handles (sic) the drug evidence in this case?
A: Yes, ma’am.

Q: And from the time that were handed, the one that you
allegedly bought, to the time that you frisked the accused in this case until
the time of the arrival of the required witnesses, they were all unmarked?
A: No markings yet, Ma’am.

Upon the Honorable Court’s clarificatory questions, the witness gave the
same information:

COURT TO WITNESS:
Q: Where did you conduct the marking, Mr. Witness?
A: At the place of the incident, your Honor.

Q: At what time did you conduct the marking?

A: I think it was already 10:15, your Honor.

Q: How about the inventory?

A: Same time, your Honor.

Further, the witnesses – who were supposed to insulate against the

possibility of tampering, planting or contamination of the evidence were
not present during the seizure of the specimen from the accused, and
arrived only at the time of the alleged marking and conduct of the
inventory. In his Sinumpaang Salaysay, PAT Fajardo narrated:

Copy from p. 8 , 2nd to the last paragraph to p. 9, Pae 2 to 4.

 8

The presence of witnesses is imperative during the actual seizure, as

explained in People of the Philippines vs. Joshua Que:5
The presence of third-party witnesses is imperative, not only during the
physical inventory and taking of pictures, but also during the actual
seizure of items.1âwphi1 The requirement of conducting the inventory
and taking of photographs "immediately after seizure and confiscation"59
necessarily means that the required witnesses must also be present during
the seizure or confiscation. This is confirmed in People v. Mendoza, 60
where the presence of these witnesses was characterized as an "insulating
presence [against] the evils of switching, 'planting' or contamination":61
Similarly, P/Insp. Lim did not mention in his testimony, the relevant
portions of which are quoted hereunder, that a representative from the
media or the Department of Justice, or any elected public official was
present during the seizure and marking of the sachets of shabu, as follows:
....
The consequences of the failure of the arresting lawmen to comply with
the requirements of Section 21 (I), supra, were dire as far as the
Prosecution was concerned. Without the insulating presence of the
representative from the media or the Department of Justice, or any elected
public official during the seizure and marking of the sachets of shabu, the
evils of switching, "planting" or contamination of the evidence that had
tainted the buy-busts conducted under the regime of RA No. 6425
(Dangerous Drugs Act of 1972) again reared their ugly heads as to negate
the integrity and credibility of the seizure and confiscation of the sachets
of shabu that were evidence herein of the corpus delicti, and thus
adversely affected the trustworthiness of the incrimination of the accused.
Indeed, the insulating presence of such witnesses would have preserved an
unbroken chain of custody. 62

The Second Link

The breaches further widened when the second link collapsed in its
entirety. In People of the Philippines vs. del Rosario, 6 the Supreme Court
reiterated:

The second link in the chain of custody is the transfer of the

seized drugs by the apprehending officer to the investigating officer. 42 The
investigating officer shall conduct the proper investigation and prepare the
necessary documents for the proper transfer of the evidence to the police
crime laboratory for testing. Thus, the investigating officer's possession of
the seized drugs must be documented and established. 43

In this case, the identity of the investigating officer is established. His possession of
the seized drugs is documented. However, there appears to be a glaring discrepancy
between what has been established by the investigating officer and what the arresting
officers narrated: the time of the alleged turn-over of the drug specimen.

5
G.R. No. 212994, January 31, 2018.

6
G.R. No. 235658, June 22, 2020.
 9

In his Affidavit (Exhibit C ), which was adopted as his direct

testimony upon stipulation by the prosecution and the defense, Police
Officer Pardo narrated:

“That on November 30, 2020 at about 6:30 p.m. the drug

evidence, subject of the buy-bust marked as “PUL-BB” and seized
evidence with markings “KPN-1”, “KPN-2” and “ALD-3” from the
suspect Kenneth Nazario y Ponciano@Kenneth and Anthony dela
Cruz y Lumbao, wre presented and turned-over to me by arresting
Office PAT Jaypee Fajarod and at around 11:50 PM, November
30, 2020 assisted by PAT Jaypee Fajardo said drugs evidence was
turnover by the undersigned to PMAJ GINA M. CAMPOSANO
(Forensic Chemist) of Provincial Crime Laboratory for examination
to maintain the integrity with appropriate chain of custody form.
X x x”

An examination of the Chain of Custody Form reveals that the time

of the turnover from Officer Fajardo to the investigating officer is not
indicated therein.

The discrepancy militates against the regularity of the performance

of the police officers in the conduct of the buy-bust operation. It gives the
impression that the buy-bust operation had been staged, the drug specimen
having been turned-over to the duty investigator even prior to its alleged
confiscation. The variance cannot be disregarded as mere error,
considering that the chain of custody form itself does not indicate the time
the specimen had been turned over to the investigator. Que, supra,
underscored the importance of the links in ensuring the integrity of the
corpus delicti in drug cases:

What is critical in drug cases is not the bare conduct of inventory,

marking, and photographing. Instead, it is the certainty that the items
allegedly taken from the accused retain their integrity, even as they
make their way from the accused to an officer effecting the seizure,
to an investigating officer, to a forensic chemist, and ultimately, to
courts where they are introduced as evidence. Hence, the four (4)
links were underscored in Nandi:56 first, from the accused to the
apprehending officers; second, from the apprehending officers to the
investigating officers; third, from the investigating officers to the
forensic chemists; and fourth, from the forensic chemists to the
courts. The endpoints of each link (e.g., the accused and the
apprehending officer in the first link, the forensic chemist and the
court in the fourth link) are preordained, their respective existences
not being in question. What is prone to danger is not any of these end
points but the intervening transitions or transfers from one point to
another.

Section 21 (1)'s requirements are designed to make the first and

second links foolproof. Conducting the inventory and photographing
immediately after seizure, exactly where the seizure was done, or at a
 10

location as practicably close to it, minimizes, if not eliminates, room

for adulteration or the planting of evidence. The presence of the
accused, or a representative, and of third-party witnesses, coupled
with their attestations on the written inventory, ensures that the items
delivered to the investigating officer are the items which have
actually been inventoried.

With the gaps in the chain of custody unbridged in the first two links, it
follows that the examination of the forensic chemist of the specimen
turned over to her becomes suspect. There had been no insulation
against tampering from the very beginning, there is no assurance that the
specimen which the forensic chemist examined had been actually seized
from the accused. There is no moral certainty that the drug specimen
presented before the Honorable Court had really been recovered from the
accused.

The possibility that the sachets confirmed to contain illegal substances after
examination by the forensic chemist and presented to the Honorable Court are
not the same ones seized by the arresting officers and turned over to the
investigator stares at the face, fuming misgivings as to their identity. Lescano
vs. People of the Philippines7 is enlightening:

“In every criminal prosecution for possession of

illegal drugs, the Prosecution must account for the custody
of the incriminating evidence from the moment of seizure and
confiscation until the moment it is offered in evidence. That
account goes to the weight of evidence. It is not enough that
the evidence offered has probative value on the issues, for
the evidence must also be sufficiently connected to and tied
with the facts in issue. The evidence is not relevant merely
because it is available but that it has an actual connection
with the transaction involved and with the parties thereto.
This is the reason why authentication and laying a
foundation for the introduction of evidence are important.

In Malilin v. People, this court explained that the

exactitude required by Section 21 goes into the very nature
of narcotics as the subject of prosecutions under Republic
Act No. 9165:

Indeed, the likelihood of tampering, loss or mistake

with respect to an exhibit is greatest when the exhibit is small
and is one that has physical characteristics fungible in
nature and similar in form to substances familiar to people
in their daily lives. Graham vs. State positively
acknowledged this danger. In that case where a substance
7
G.R. No. 214490, January 13, 2016.
 11

later analyzed as heroin—was handled by two police officers

prior to examination who however did not testify in court on
the condition and whereabouts of the exhibit at the time it
was in their possession—was excluded from the prosecution
evidence, the court pointing out that the white powder seized
could have been indeed heroin or it could have been sugar or
baking powder. It ruled that unless the state can show by
records or testimony, the continuous whereabouts of the
exhibit at least between the time it came into the possession
of police officers until it was tested in the laboratory to
determine its composition, testimony of the state as to the
laboratory’s findings is inadmissible.

A unique characteristic of narcotic substances is that

they are not readily identifiable as in fact they are subject to
scientific analysis to determine their composition and
nature. The Court cannot reluctantly close its eyes to the
likelihood, or at least the possibility, that at any of the links
in the chain of custody over the same there could have been
tampering, alteration or substitution of substances from
other cases—by accident or otherwise—in which similar
evidence was seized or in which similar evidence was
submitted for laboratory testing. Hence, in authenticating the
same, a standard more stringent than that applied to cases
involving objects which are readily identifiable must be
applied, a more exacting standard that entails a chain of
custody of the item with sufficient completeness if only to
render it improbable that the original item has either been
exchanged with another or been contaminated or tampered
with.

Compliance with the chain of custody requirement

provided by Section 21, therefore, ensures the integrity of
confiscated, seized, and/or surrendered drugs and/or drug
paraphernalia in four (4) respects: first, the nature of the
substances or items seized; second, the quantity (e.g.,
weight) of the substances or items seized; third, the relation
of the substances or items seized to the incident allegedly
causing their seizure; and fourth, the relation of the
substances or items seized to the person/s alleged to have
been in possession of or peddling them. Compliance with this
requirement forecloses opportunities for planting,
contaminating, or tampering of evidence in any manner.”

Prosecution’s evidence
Insufficient
 12

In Garcia,8 the Supreme Court recognized the downside of buy-bust

operations:

“A buy-bust operation gave rise to the present

case. While this kind of operation has been proven to be an
effective way to flush out illegal transactions that are
otherwise conducted covertly and in secrecy, a buy-bust has
a significant downside that has not escaped the attention of
the framers of the law. It is susceptible to police abuse, the
most notorious of which is its use as a tool for
extortion. In People v. Tan, this Court itself recognized
that by the very nature of anti-narcotics operations, the need
for entrapment procedures, the use of shady characters as
informants, the ease with which sticks of marijuana or grams
of heroin can be planted in pockets of or hands of
unsuspecting provincial hicks, and the secrecy that inevitably
shrouds all drug deals, the possibility of abuse is great. Thus,
courts have been exhorted to be extra vigilant in trying drug
cases lest an innocent person is made to suffer the unusually
severe penalties for drug offenses. Accordingly, specific
procedures relating to the seizure and custody of drugs have
been laid down in the law (R.A. No. 9165) for the police to
strictly follow. The prosecution must adduce evidence that
these procedures have been followed in proving the elements
of the defined offense.”

The holding in People vs. Andaya9 provides the denouement for the
accused-movant’s arguments:

“Proof of the transaction must be credible and

complete. In every criminal prosecution, it is the State, and
no other, that bears the burden of proving the illegal sale of
the dangerous drug beyond reasonable doubt. This
responsibility imposed on the State accords with the
presumption of innocence in favor of the accused, who has
no duty to prove his innocence until and unless the
presumption of innocence in his favor has been overcome by
sufficient and competent evidence.”

In the instant case, the relation of the drugs presented and offered in
evidence by the prosecution to the ones allegedly seized from the accused is
consumed in a dark cloud of doubt. Compliance with the mandatory
requirements of Section 21 of RA 9165 is plainly lacking, as the witnesses were
unable to satisfactorily justify deviation from the accepted norms of
engagement. And more importantly, the chain of custody of the seized drug
evidence – the element that proves corpus delicti – had gaps unbridged from the
first link to the last.

8
Supra, note 1.
9
G.R. No. 183700, 13 October 2014.
 13

With the prosecution’s failure on those accounts, the case against

accused-movant should be dismissed.

PRAYER

WHEREFORE, premises considered, it is respectfully prayed of the

Honorable Court that this Demurrer to Evidence be granted and that the
criminal charges of Violation of Sections 5 and 11 of Article II of R.A. 9165
against the accused JOHN KENNETH NAZARIO y Ponciano be DISMISSED
and accused be ACQUITTED of the charges against him.

Other reliefs just and equitable are likewise prayed for.

City of Malolos, Bulacan, August 20, 2021.

MARIA ELEANOR J. EUSEBIO-CRUZ

Counsel for Accused
Rm. 7 G/F HBCC Annex Building,
Capitol Compound, City of Malolos, Bulacan
Roll of Attorney’s No. 51316
IBP No. 115050/01-30-2020
PTR No. 4247513/01-15-2020
MCLE Compliance No. VI-0025914/04-29-2019
E-mail Address: gie.euz@gmail.com
Contact No. (044) 797-5961

Copy furnished:

OFFICE OF THE PROVINCIAL PROSECUTOR

Capitol Compound, City of Malolos, Bulacan

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