REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

NATIONAL CAPITAL JUDICIAL REGION
Branch 161
Pasig City

PEOPLE OF THE PHILIPPINES,

CRIM CASE NO.
R-PSG-20-02543-CR

-versus- For: Violation of Sec 28 (a) in

relation to Sec. 28 € of RA 10591

GEORGIE GEVERO y ELEUTERIO,

Accused
x-----------------------------------------------x

COMMENT/OPPOSITION
(ON FORMAL OFFER OF EVIDENCE OF PROSECUTION)

Accused GEORGIE GEVERO y ELEUTERIO, by the undersigned counsel

from the Public Attorney’s Office (PAO), unto this Honorable Court, respectfully
manifests the following comment/opposition on the formal offer by the
prosecution:

1. Exhibit “A”, the Sinumpaang Salaysay of PCpl Jomar Banaag, is vehemently

objected to for being self-serving and for being inadmissible for violation of
Constitutional right of the person against unreasonable search and seizure,
and for violations of chain of custody under Section 21 of RA 9165.

2. Exhibit “B” to “B-26”, the photograph of one 9mm caliber pistol, one magazine
for 9mm caluber pistol, and photos of 24 ammunition, are vehemently
objected to for being self-serving and for being inadmissible for violation of
Constitutional right of the person against unreasonable search and seizure,
and for violations of chain of custody under Section 21 of RA 9165.

3. Exhibit “C”, the Request for Verification of Records dated November 29, 2020,
is vehemently objected to for being self-serving and for being inadmissible for
violation of Constitutional right of the person against unreasonable search and
seizure, and for violations of chain of custody under Section 21 of RA 9165.

4. Exhibit “D”, the Initial Result of Firearms Record Verification, dated December
11, 2020, is vehemently objected to for being self-serving and for being
inadmissible for violation of Constitutional right of the person against
unreasonable search and seizure, and for violations of chain of custody under
Section 21 of RA 9165.

5. Exhibit “E” to “E-1” and “F”, the photos of one 9mm caliber pistol with serial
number and photo of one magazine for 9mm caliber pistol, are vehemently
objected to for being self-serving and for being inadmissible for violation of
Constitutional right of the person against unreasonable search and seizure,
and for violations of chain of custody under Section 21 of RA 9165.

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6. Exhibit “H”, “H-1” and “H-2”, the Firearm Identification Report, signature of
Michael Villamayor and Conclusion/result portion of the physical examination
and test firing, are vehemently objected to for being self-serving and for being
inadmissible for violation of Constitutional right of the person against
unreasonable search and seizure, and for violations of chain of custody under
Section 21 of RA 9165.

PRAYER

WHEREFORE, premises considered, it is respectfully prayed of the

Honorable Court that the Comments/Opposition be duly considered in the
resolution of the Prosecution’s Formal Offer of Evidence and DENY the offered
evidence for being INADMISSIBLE and violative of existing laws and
jurisprudence.

Equitable and just reliefs under the premises are likewise prayed for.

Respectfully submitted.

Pasig City, October 2, 2023.

DEPARTMENT OF JUSTICE
PUBLIC ATTORNEY’S OFFICE
Counsel de oficio
3rd Floor, Bahay Aruga – PSWD
Eusebio Building, City Hall Compound
Caruncho cor Market Avenue
San Nicolas, Pasig City

By

ATTY. MARIA GICEL T. CAMBRI

Public Attorney II
Roll of Attorneys No. 70275
IBP Member No. 234215 / June 13, 2022
MCLE Compliance No. VII-0015885

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 NOTICE

Branch Clerk of Court

Regional Trial Court
Branch 161, Pasig City

Greetings!

Kindly submit the foregoing pleading for the kind consideration and
approval of the Honorable Court immediately upon receipt hereof.

ATTY. MARIA GICEL T. CAMBRI

Copy Furnished:
SACP AILEEN SABARRE
Public Prosecutor
Office of the City Prosecutor
7th floor, Hall of Justice, Pasig City

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