Omnibus Motion

Republic of the Philippines
National Capital Judicial Region

METROPOLITAN TRIAL COURT
Branch 66
Makati City
PEOPLE OF THE PHILIPPINES,

Complainant,
-versus- CRIMINAL CASE NO.

16-04118
MARY GRACE GARCIA,

Accused.
x ---------------------------------- x
OMNIBUS MOTION TO FILE OBJECTIONS TO THE

PROSECUTION’S FORMAL OFFER OF EVIDENCE DATED
March 7, 2019 WITH LEAVE OF COURT AND ATTACHED
OBJECTIONS AND ENTRY OF APPEARANCE
Accused MARY GRACE GARCIA, through her counsel

the CENTRO ESCOLAR UNIVESITY, SCHOOL OF LAW AND
JURISPRUDENCE – OFFICE OF THE LEGAL AID, most
respectfully submit the foregoing:
1. That the Academic Year 2019-2020 had recently began

and a new batch of senior legal interns of the Centro
Escolar University, School of Law and Jurisprudence
(CEU) – Office of the Legal Aid (OLA) have just been
appointed;
2. That at the start of the Semester, the senior legal interns

were informed of the Court’s Order dated June 25, 2019;
3. That according to the said Order, prosecution witnesses

were subject to cross-examination; and that the
prosecution filed its Formal Offer of Evidence on March
7, 2019;
4. According to Section 36, Rule 132 of the Rules on

Evidence, an offer of evidence in writing shall be
PROSECUTION’S FORMAL OFFER OF EVIDENCE
DATED MARCH 7, 2019 WITH LEAVE OF COURT AND
ATTACHED OBJECTIONS AND ENTRY OF APPEARANCE
PEOPLE OF THE PHILIPPINES vs. MARY GRACE GARCIA
CRIMINAL CASE NO. 16-04118
x ----------------------------------------------------------------------------------------- x
objected to within three (3) days after notice of the

unless a different period is allowed by the court;
5. That the prosecution filed its Formal Offer of Evidence on

March 7, 2019 even though the presentation of their last
witnesses was only concluded on June 25, 2019;
6. That the newly assigned senior interns were not given a

reasonable opportunity to place their objections to the
Prosecution’s Formal Offer of Evidence
7. That CEU – OLA asks this Honorable Court for an

opportunity to file its Objections to the above-stated
Formal Offer of Evidence so that the law student interns
can experience and apply their knowledge on the Rules
of Evidence in drafting their objections;
8. That with the kind indulgence of this Court, the

Objections to the Prosecution’s Formal Offer of Evidence
is attached to this Omnibus Motion for its consideration.
ENTRY OF APPEARANCE
The Undersigned Supervising Lawyer and Senior Legal

Interns for the CEU - OLA most respectfully enter their
appearance for the Accused MARY GRACE GARCIA. It is most
humbly prayed that all pleadings, orders, notices, and any
processes issued by the Honorable still be sent and directed
to the CEU – OLA.
WHEREFORE, it is respectfully prayed that this

Honorable Court allow the CEU – OLA to file its Objections to
the Prosecution’s Formal Offer of Evidence dated March 7,
2019. Other just and equitable reliefs are likewise prayed for.
City of Makati, September 17, 2019.
Page 2 of 4
x ----------------------------------------------------------------------------------------- x
CENTRO ESCOLAR UNIVERSTY

SCHOOL OF LAW AND JURISPRIDENCE
OFFICE OF THE LEGAL AID
259 Sen. Gil Puyat Avenue, Makati City
(+63)2 843-0300 loc. 102
_____________________________
Supervising Lawyer
Roll No. ________
PTR No. _________ | _________, 2019 | _________
IBP No. ___________ | __________, 2019 | _________
MCLE Compliance No. ___________ | ___________
_______________
Senior Legal Intern of the CEU – OLA
_______________
_______________
_______________
Page 3 of 4
x ----------------------------------------------------------------------------------------- x
Copy furnished:
ATTY. DIOMER L. PRIELA

Counsel for the Complainant
Assistant City Prosecutor
Office of the City Prosecutor
16th Flr., New Makati City Hall Bldg.
J.P. Rizal St., Makati City
EXPLANATION
Service on the adverse party cannot be done personally

as the CEU - OLA at present does not have a permanent
messenger and therefore has no adequate manpower to serve
pleadings personally. The temporary messenger still has to
file pleadings in cases of equal importance.
(Supervising Lawyer)
NOTICE OF HEARING
Branch Clerk of Court

Metropolitan Trial Court
Branch 66
Makati City
Greetings: Please take notice that the foregoing

Omnibus Motion shall be submitted for the consideration of
the Honorable Court on ________ at ________ (a.m./p.m.)
or as soon as counsel and matter may be heard.
(Supervising Lawyer)
Page 4 of 4

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Republic of the Philippines

National Capital Judicial Region

PEOPLE OF THE PHILIPPINES,

-versus- CRIMINAL CASE NO.

MARY GRACE GARCIA,

OMNIBUS MOTION TO FILE OBJECTIONS TO THE

Accused MARY GRACE GARCIA, through her counsel

1. That the Academic Year 2019-2020 had recently began

2. That at the start of the Semester, the senior legal interns

3. That according to the said Order, prosecution witnesses

4. According to Section 36, Rule 132 of the Rules on

objected to within three (3) days after notice of the

5. That the prosecution filed its Formal Offer of Evidence on

6. That the newly assigned senior interns were not given a

7. That CEU – OLA asks this Honorable Court for an

8. That with the kind indulgence of this Court, the

The Undersigned Supervising Lawyer and Senior Legal

WHEREFORE, it is respectfully prayed that this

City of Makati, September 17, 2019.

CENTRO ESCOLAR UNIVERSTY

ATTY. DIOMER L. PRIELA

Service on the adverse party cannot be done personally

Branch Clerk of Court

Greetings: Please take notice that the foregoing

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