REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

SIXTH JUDICIAL REGION
BAGO CITY
Branch 62

PEOPLE OF THE PHILIPPINES,

Criminal Case Nos. 4313 to 4315

- versus - For: Sexual Abuse in relation to
R.A. 7610

EDDIE L. BAILON J..R,

Accused.

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COMMENT
(to the Prosecution’s Formal Offer of Exhibits)

Accused, Eddie Bailon, Jr., by counsel, respectfully submits his

comment to the Prosecution’s formal offer of documentary exhibits, as
follows:

EXHIBIT DESCRIPTION COMMENT

A and its sub- Sworn Statement Accused admits the authenticity
markings. of Nicole and due execution of the exhibit
Villacorta and the but objects to the purpose for
signatures of which it is offered for being self-
Nicole and Frecile serving and uncorroborated by the
Villacorta affixed evidence on record.
thereon.
To stress: the allegations made in
Nicole Villacorta’s Sworn
Statement are not evidence per se.

And, aside from her bare

allegations that the Accused
touched and sucked her private
parts, on record has corroborated
such claim.

Exhibit B and Sworn Statement Accused admits the authenticity

its sub- of Princess and due execution of the exhibit
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markings. Villacorta and her but objects to the purpose for
signature thereon. which it is offered for being self-
serving, misleading, and
uncorroborated by the evidence on
record.

To stress: the allegations made in

Princess Villacorta’s Sworn
Statement are not evidence per se.

And, in fact, when Princess

Villacorta was asked by this Court,
during her direct examination,
whether the Accused inserted his
finger inside her vagina, she said
no. Princess further said that the
Accused did not even took of her
shorts.

Exhibit C and Sworn Statement Accused admits the authenticity

its sub- of Queeneth and due execution of the exhibit
markings. Villacorta and her but objects to the purpose for
signature thereon. which it is offered for being self-
serving, misleading, and
uncorroborated by the evidence on
record.

To stress: the allegations made in

Queeneth Villacorta’s Sworn
Statement are not evidence per se.

And, when Queeneth Villacorta

was asked by this Court, during
her direct examination, whether
the Accused inserted his finger
inside her vagina, she said no,
same as Princess Villacorta’s
answer. Queeneth further said that
the Accused did not even took of
her shorts, same as Princess
Villacorta’s answer.

Exhibit D. Sworn Statement Accused admits the authenticity

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 of Frecile and due execution of the exhibit
Villacorta and her but objects to the purpose for
signature thereon. which it is offered for being self-
serving, irrelevant, misleading, and
uncorroborated by the evidence on
record.

To stress: the allegations made in

Frecile Villacorta’s Sworn
Statement are not evidence per se.

Furthermore, during her direct and

cross examination, Frecile
Villacorta admitted that she did not
see the Accused touch the vagina
of Princess Villacorta on June 23,
2018, as she was at the back of her
house during the alleged incident.

Exhibit E, F, Medico Legal The Accused objects to the offer of

and G. Certificate of the exhibits as the physician who
Nicole Villacorta, issued the Medical Certificates,
Princess Villacorta, Dr. Georgina M. Hufanda, was not
and Queeneth presented in Court to testify and
Villacorta, authenticate the certificates.
respectively.

Exhibits H, I, Birth Certificate of The accused admits the existence

J, and its sub- Nicole Villacorta, and due execution of the Birth
markings. Princess Villacorta, Certificates.
and Queeneth
Villacorta,
respectively.
Exhibits K Excerpt and The Accused admits the
and its sub- Narrative of Police authenticity and due execution of
markings. Blotter dated June the exhibits but objects to the
29, 2018. purpose for which it is offered for
being self-serving and misleading.

RELIEF

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 WHEREFORE, premises considered, the Accused respectfully prays
that an Order be issued by this Honorable Court denying the admission of
the Prosecution’s Exhibits based on the cited grounds.

Other equitable reliefs are likewise prayed for.

Bacolod City for the City of Bago, July 10, 2020.

CATACUTAN & SINCO

LAW OFFICES
Counsel for the Accused
Door No. 4, 2nd Floor
Esteban - Magdalena Building
Hernaez Street, Barangay 38, Bacolod City,
Negros Occidental, 6100
Email Address: caslawoffices@gmail.com
Telephone No.: 034-447-5365

By:

ACE JOSEPH B. CATACUTAN

PTR No. 8336646/01-7-20/Bacolod City
IBP LRN No. 112868/01-23-20
Negros Occidental Chapter
Attorney’s Roll No. 64091
MCLE Compliance No. V-0008664; 04-14-2022

GABRIEL P. SINCO
PTR No. 7554400/ 01-23-19/Bacolod City
IBP LRN No. 112868/01-23-20
072264/01-25-2019
Negros Occidental Chapter
Attorney’s Roll No. 67606
MCLE Compliance No. VI-0008750; 04-14-2022

Copy Furnished:

The Honorable Clerk of Court

RTC-Branch 62
Bago City.

Hon. Maria Christy E. Uriarte

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Deputy City Prosecutor
Bago City.