Republic of the Philippines

National Capital Judicial Region

Regional Trial Court
Branch 135, Makati City
People of the Philippines,
Plaintiff,

Criminal Case No. 111795

-versusFor: Violation of RA 9165,
sec.5
Sonny Cabrera Ng @Shi Shuang Wu,
Yang Chin Ti, Shengxi Li, and Sonny Co,
Accused.
x----------------------------------------------------x
People of the Philippines,
Plaintiff,
Criminal Case No. 111796 For: Violation of RA
-versus9165, sec.11
Shengxi Li, and Sonny Co,
Accused.
x----------------------------------------------------x
People of the Philippines,
Plaintiff,
Criminal Case No. 111797 For: Violation of RA
-versus9165, sec.11
Sonny Cabrera Ng @Shi Shuang Wu,
and Yang Chin Ti,
Accused.
x----------------------------------------------------x
COMMENT ON/ OPPOSITION TO
(Prosecutions Formal Offer of Exhibits
dated 18 March 2015)
ACCUSED, through the undersigned counsel and unto
this Honorable Court, most respectfully states that:
On 20 April 2015, accused filed their Opposition to the
Prosecutions Motion to Admit Formal Offer of Evidence by
registered mail. Therein, the accused prayed that said
motion be denied or in the alternative, they be allowed to
submit their Comment/ Opposition to the Prosecutions
Formal Offer of Exhibits. Hence, the instant Comment/
Opposition.

Accused hereby respectfully submits the following

comments on and/ or objections to, the said Formal Offer of
Evidence:
1. Exhibits A, B, C, D and its sub-markings.
Accused admit only the existence of the documents.
They are objected to for being self-serving and bias.
Further, they do not prove the purposes for which they
are being offered.
2. Exhibits E, F, G, H and sub-markings. Accused
objects to these exhibits as it appears that they have
not yet been identified in court.
3. Exhibits I, I-4and sub-markings. Accused admits
only the existence of these documents.
4. Exhibit J. Accused objects to its admissibility as
secondary evidence considering the original document
has not been shown to be lost, destroyed or that it
cannot be produced in court; nor has its execution,
existence and cause of
unavailability been shown
according to the rules on evidence. Therefore, the
exhibit is incompetent to prove the contents of the
writing. Moreover, they are self-serving, hearsay and
misleading.
5. Exhibits K, L, M, N, O, P and sub-markings.
Accused admits the existence only but objects to their
admissibility with respect to the purposes for which
they are being offered. Clearly, these documents are
self-serving.
6. Exhibits Q and R. No further comment.
7. Exhibit S and sub-markings. Accused objects to the
admissibility of the exhibits with respect to the purpose
for which they are being offered as they do not indicate
the alleged validity of the operation and the legality of
the arrest.
8. Exhibits T, U, V, W, X, Y and sub-markings.
Accused objects to the admissibility of the exhibits with
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respect to the purposes for which they are being

offered considering they do not prove that accused
Sonny Cabrera sold shabu to the poseur buyer, does
not show that the items were recovered from any of the
accused, and does not prove the keeping of the alleged
recovered evidence.
9. Exhibits Z, AA, BB, CC and sub-markings.
Accused objects to their admissibility with respect to
the purposes for which they are being offered and for
being self-serving.
PRAYER
WHEREFORE, Accused respectfully prays that the
foregoing comments on and/ or objections to the exhibits
offered by the prosecution be considered in resolving the
Prosecutions Formal Offer of Exhibits.
Accused likewise prays for such other relief as may be
deemed just and equitable.
RESPECTFULLY SUBMITTED.
27 April 2015; Pasig City for Makati City.
DEFENSOR LANTION BRIONES VILLAMOR &
TOLENTINO LAW OFFICES
Counsel for all Accused
Unit 2604-A, 26th Floor, East Tower, Philippine Stock
Exchange Centre, Exchange Road, Ortigas Center
1605 Pasig City, Metro Manila
by:
FRANCISCO G. TOLENTINO
Attorneys Roll No. 60970
IBP No. 013221; January 14, 2015; Laguna
PTR No. 0679422; January 13, 2015; Quezon City
MCLE Compliance No. IV-0013692
Issued on: March 11, 2013
Copy furnished: (by personal service)
HON. LILY JOY L. PATRIA
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ASSISTANT CITY PROSECUTOR

Office of the City Prosecutor
Makati City