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Republic of the Philippines

11th Judicial Region


1st Municipal Circuit Trial Court
City of Panabo, Davao del Norte

PEOPLE OF THE PHILIPPINES,


Plaintiff,

-versus- CRIM. CASE NO. 12345


FOR: ACTS OF
LACIVIOUSNESS

MANG KANOR,
Accused.
x---------------------x

MOTION FOR REINVESTIGATION

ACCUSED, through the undersigned counsel, to this Honorable


Court, most respectfully state:

1. That this case was filed by the Honorable Asst. State City
Prosecutor without the benefit of the accused answering the charges against
him;

2. That while the resolution of the Honorable Asst. City


Prosecutor states that the accused was unable to submit his countervailing
evidence despite numerous efforts of the Office to inform him of the
complaint filed against him and the scheduled preliminary investigation,
nevertheless, the accused was not really informed that there was a case filed
against him without his fault. In fact, the information was filed on January
2017, and that the accused was arrested only this April 2017 when the
accused went to the police station to testify in a stabbing incident, however,
when found out by the policemen the name of the accused, that there was a
standing warrant against him, the policemen instantly arrested the accused.

3. That this motion is anchored on the fact, that accused in this


case has a valid defense ranged against the sole affidavit of the complainant
without any corresponding evidence as to the fact ownership of the said
grinder subject of this case except the positive assertion of the private
complainant;

4. A person cannot be held liable for acts of lasciviousness were


the private complainant consented to the doing of the malicious act. It is the
private complainant who should be faulted by consenting the accused
touching her breast and vagina. When she noticed that the conductor and
some passenger were aware that they are having a good time. She
immediately shouted to save her reputation and to the detriment of the
accused.

5. That the witness conductor is lying as he was offered by the


private complainant a big amount of money in order to testify in favor of her
and against the accused.

6. That the accused and private complainant are former lovers and
there still existing a feeling toward each other which made private
complainant consenting the doing of the sexual advances.

WHEREFORE, premises considered, it is most respectfully prayed of


this Honorable Court, that the foregoing motion be favorably granted.

City of Panabo, Davao del Norte, February 14, 2016.

(Sgd.) Atty. Lionel Messi


Counsel for Accused
13-69 Barracks Building, Marikina
IBP NO. 87123-7/19/12-AC
PTR NO. 669913/21/12-AC
Roll No. 99998
MCLE Exempt
(Admitted to the bar: April 6, 2012)

NOTICE AND REQUEST FOR HEARING

The Branch Clerk of Court


1st Municipal Circuit Trial Court

City Prosecutor
City of Panabo

Sir:

Please calendar the foregoing Motion for hearing on February 25,


2016 at 10:30 o’clock in the morning or at the earliest possible calendar of
this Honorable Court, sans personal appearance of undersigned counsel.
Atty. Lionel Messi

Copy furnished:

Atty. Cristiano Ronaldo


CITY PROSECUTOR
City Prosecutor’s Office
City of Panabo
Republic of the Philippines
st
1 Municipal Circuit Trial Court
11th Judicial Region
Panabo City, Davao del Norte

PEOPLE OF THE PHILIPPINES,


Plaintiff,
CRIMINAL CASE NO.
12345
-versus-
For:
ACTS OF LASCIVIOUSNESS
MANG KANOR,
Accused,

x------------------------------------------------x

JUDICIAL AFFIDAVIT

The following statements in this Affidavit were taken at the Public


Attorney’s Office, Hall of Justice, Barangay Poblacion, Panabo City, Davao
del Norte before Public Attorney III / Officer-in-Charge Lionel Messi
relative to Criminal Case No. 12345 entitled PEOPLE OF THE
PHILIPPINES VERSUS MANG KANOR for ACTS OF
st
LASCIVIOUSNESS and filed before the 1 Municipal Circuit Trial Court of
Panabo City, Panabo City, Davao del Norte. The affiant is aware that he
could be liable for perjury if he maliciously and intentionally gives false
answers in this judicial affidavit.

Q1. Please state your name, age, address and employment?


A1. I am Mang Kanor, of legal age, resident of Purok 2, Barangay
Cabidianan, Nabunturan, Compostela Valley Province and an employee of
the Provincial Government of Compostela Valley.

Q2. You are the accused in this case?


A2. Yes, I am the accused in this case.

Q3. You are accused that at past 9 evening of December 23, 2015, in the city
of Panabo, Davao del Norte, you rode a passenger van from Panacan to
Panabo City. On the same date, you saw Aling Moana inside the passenger
van and touched her breast and vagina while she was asleep, what can you
say to these accusations?
A3. That is not true.

Q4. You said that the accusations are not true, where were you at past 9
evening of December 23, 2015?
A4. I was inside a passenger van travelling from Panacan to Panabo City.
Q5. So you are riding the same passenger van with the private complainant?
A5. Yes.

Q6. Did you smashed the breast and touched the vagina of the private
complainant?
A6. Yes, but she consented to what I did since she know that I am her ex-
boyfriend.

Q7. What is her reaction when you smashed her breast and touched her
vagina?
A7. She just let me touched it and she was moaning silently.

Q8. If she really consented to the smashing why did she push you away and
shouted at you?
A8. Because somebody saw that I was smashing her breast and touching her
vagina.

Q9. What do you think why she shouted at you when in fact she consented
when you smashed her breast and touched her vagina as you said.
A9. She did it to save her reputation as somebody inside the van saw that
I’m smashing her breast and touching her vagina. It was her revenge to me
since I dump her when we are in relationship before.

Q10. Do you affirm the truthfulness of all the statements that you gave in
this Judicial Affidavit?
A10. Yes sir.

In witness whereof, I hereby set my hand this February 2, 2016 at


Panabo City, Davao del Norte.

MANG KANOR
Affiant

SUBSCRIBED AND SWORN to before me this February 2, 2016 at


Panabo City, Davao del Norte, affiant appearing personally before with his
competent evidence of identity and presenting to me a document entitled
Judicial Affidavit dated February 1, 2016 and who signed the said document
in my presence and sworn that he understood the contents thereof and that
the same was his free and voluntary act and deed.

LIONEL A. MESSI
Public Attorney III
(Pursuant to RA 9406)
SWORN ATTESTATION

I, ATTY. LIONEL A. MESSI, of legal age, Filipino, single and with


office address at Public Attorney’s Office – Panabo District Office, Hall of
Justice, Barangay Poblacion, Panabo City, Davao del Norte, after having
been duly sworn to in accordance with law, do hereby depose and state:

That I am the lawyer who conducted the examination of MANG


KANOR, accused in CRIMINAL CASE. NO. 12345 entitled PEOPLE OF
THE PHILIPPINES VERSUS MANG KANOR and file with the 1st
Municipal Circuit Trial Court of Panabo City, Panabo City, Davao del
Norte.

That I faithfully recorded the questions therein asked and the


corresponding answers that the witness gave;

That the questions and answers are in the language known to the
affiant;

That neither I nor any person then present coached the affiant
regarding his given answers;

That a false attestation shall subject the undersigned to disciplinary


action including disbarment;

That I am executing this attestation in compliance with Administrative


Circular No. 12-8-8-SC.

In witness whereof, I hereby set my hand this February 2, 2016 at


Panabo City, Davao del Norte.

ATTY. LIONEL A. MESSI


Affiant
Employee ID no. PAO-12345

SUBSCRIBED AND SWORN TO before me this February 2, 2016 at the


Public Attorney’s Office-Panabo District Office, Panabo City, Davao del
Norte, Philippines, affiant ATTY. LIONEL A. MESSI, appearing before me
with her competent proof of identity and presenting to me a document
entitled Sworn Attestation dated February 2, 2016 and who signed said
document in my presence and sworn that he understood the contents thereof
and at the same was his free and voluntary act and deed.
Luis B. Suarez
Public Attorney I
(Pursuant to RA 9406)

Copy Furnished:

City Prosecution Office


Panabo City, Davao del Norte
Republic of the Philippines
st
1 Municipal Circuit Trial Court
11th Judicial
Panabo City

PEOPLE OF THE PHILIPPINES,


Petitioner,

-versus-

CRIMINAL CASE NO. 12345


MANG KANOR,
Respondent.
x-------------------------------------x

MOTION FOR POSTPONEMENT

COMES NOW Defendant, thru undersigned counsel, unto this


Honourable Court respectfully states:

1.That the above entitled case is set for [*INITIAL] hearing on March
30 ,2016;

2.That counsel for defendant is afflicted with influenza and is now


under the medical care of Dr. Salazar. A copy of the physician’s certificate
under is hereto attached [*REASONS: STILL
COLLATING/STUDYINGCASE AND ITS EVIDENCE, WITNESS IS
UNAVAILABLE ETC].

WHEREFORE, it is respectfully prayed that the hearing set on March


30,2017 be reset to another day preferably on the first week of April 2017 or
at the convenience of this Honorable Court.

Panabo City, Philippines, March 25, 2017

Sgd. ATTY. Lionel A. Messi


Counsel for the Defendant
(Notice of Hearing)
(Proof of Service and Explanation)
Republic of the Philippines
1st Municipal Circuit Trial Court
11TH Judicial Region
Panabo City

PEOPLE OF THE PHILIPPINES,


Complainant,

-versus- CRIM. CASE NO.


12345
For: FOR ACTS OF
LASCIVIOUSNESS

MANG KANOR,
Accused.
x----------------------------------------x

MOTION FOR LEAVE TO FILE


DEMURRER TO EVIDENCE

The accused MANG KANOR, through the undersigned counsel, unto


this Honorable Court most respectfully professes:

1. That the prosecution in the above entitled case has already rested
its case.

2. That the defense believes that the evidence of the prosecution


against the accused is insufficient to establish the guilt of the
accused beyond reasonable doubt, thus the defense prays for leave
to file demurrer to evidence in accordance with Section 23, Rule
119, of the Rules of Criminal Procedure.

WHEREFORE, premises on the foregoing consideration and in the


highest interest of justice, it is most respectfully prayed of this Honorable
Court that the aforesaid motion be granted.
April 20, 2016, Panabo City, Philippines.

ATTY. LIONEL A. MESSI


Counsel for the Accused
REPUBLIC OF THE PHILIPPINES
st
1 MUNICIPAL CIRCUIT TRIAL COURT
11th JUDICIAL REGION
PANABO CITY

PEOPLE OF THE PHILIPPINES,


Plaintiff,

- versus – Crim. Case No. 12345


For: ACTS OF
LASCIVIOUSNESS

MANG KANOR,
Accused.
x ----------------------------------------------- x

DEMURRER TO EVIDENCE

The Accused MANG KANOR, through the undersigned counsel,


most respectfully submits its Demurrer to Evidence and avers:

BASIS FOR THE DEMURRER

It is incumbent upon the prosecution to adduce evidence sufficient to


prove beyond reasonable doubt (a) the commission of the crime, and (b) the
precise degree of participation therein by the accused. The charges against
an accused must be dismissed if there is no competent or sufficient evidence
adduced that would sustain the charges against him, should the same be
raised in a demurrer to the evidence. Section 23, Rule 119 of the Revised
Rules of Criminal Procedure provides:
“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”
It is well-settled rule that conviction for a criminal offense should be
based on clear and positive evidence and not on mere assumption. (Gaerlan
vs. CA 179 SCRA 20). The burden lies upon the prosecution to prove the
guilt of the accused beyond reasonable doubt rather that upon the accused to
prove that he is in fact innocent. (People vs. Lati, 184 SCRA 336). Failing
in this, the presumption of innocence will prevail. (Sec. 1 (a) Rule 115).

ARGUMENTS/DISCUSSION

The only witness for the prosecution was LEBRON JAMES. It


cannot be overemphasized that the affidavit of the private complainant and
the testimony of said witness showed that he had no personal knowledge of
the alleged acts of lasciviousness that was committed on 23 December 2015.
Moreover what is more dubious is that the affidavit of said complainant was
done on 25 January 2016, more than one (1) month after the alleged incident
took place. Said witness clearly did not see the alleged molestation as he
was seated at the right side of the van calling for passengers. Private
complainant consented to the doing of the act considering that the accused is
her former boyfriend and lover. It was highly improbable for the accused to
carry out such act without the consent of the private complainant as there
were few passengers inside the van. If she dislikes such sexual advances, the
most likely reaction of a victim is to slap and shout while inside the van. But
she just shouted when some passengers of the passenger van saw that they
are enjoying and having a good time. It must also be noted that the accused
and the private complainant are former lovers. The motive of the private
complainant is to put the accused into shame to take revenge to him as the
accused had repeatedly hurt the feelings of the private complainant before by
having relationships with other girls. It is evident that the motive of the
private complainant is to take revenge to her ex-boyfriend which such
revenge turned successful by putting the accused into trial for the act which
he committed with private complainant’s consent.
There is no need to discuss the other elements of acts of
lasciviousness since the prosecution was not able to establish the alleged
lewdness or lasciviousness.

Indeed, any oral or documentary evidence is hearsay by nature if its


probative value is not based on the personal knowledge of the witness but on
the knowledge of some other person not on the witness stand. (2 Regalado,
Remedial Law Compendium, 1989 6th Rev. Ed., p. 486). By virtue of this
legal aphorism, no probative value can attach to the alleged confession of
Carlos albeit no objection thereto was interposed by the defense. (People vs.
Villahermosa, (CA) 67 O.G. 4929 citing People vs. Cabral, et. Al. (unpub.)
58 Phil. 946; Vide, at p. 486). Verily, in criminal cases the admission of
hearsay evidence would be a violation of the constitutional provision that the
accused shall enjoy the right of being confronted with the witnesses
testifying against him and to cross-examine them. Moreover the court is
without opportunity to test the credibility of hearsay statements by observing
the demeanor of the person who supposedly made them (20 Am. Jur. 400-
401; cited at 7-1, Francisco, Revised Rules of Court, 1973 ed., p. 437).
People vs. MeloSantos, 245 SCRA 569, July 3, 1995.

PRAYER

WHEREFORE, premises considered, it is respectfully prayed that the


Honorable Court that this Demurrer to Evidence be granted and that the
criminal charge of Acts of Lasciviousness against the accused MANG
KANOR be DISMISSED.

Other reliefs, just and equitable, are likewise prayed for.


Panabo City, Philippines, May 28, 2016.
DEPARTMENT OF JUSTICE
Public Attorney’s Office
Rm. B-29 Hall of Justice, Panabo City

By:

ATTY. LIONEL A. MESSI


Public Attorney III

NOTICE OF HEARING

Hon. Cristiano Ronaldo


City Prosecutor

Clerk of Court
1st Municipal Circuit Trial Court

Greetings!

Please submit the foregoing Demurrer to Evidence for the approval


and consideration of the Honorable Court on 29 May 2016 at 8:30 a.m.

LIONEL A. MESSI

Copy Furnished:

Hon. Cristiano Ronaldo


City Prosecutor
REPUBLIC OF THE PHILIPPINES
OFFICE OF THE PROSECUTOR
Panabo City

ALING MOANA,
Complainant,

-versus- I.S. No.


____
For: Acts
of
Lascivious
ness
MANG KANOR,
Respondent.
x--------------------------------x

NOTICE OF APPEAL

Defendant, thru counsel and within the reglementary period


prescribed by the Rules of Court hereby files this notice of appeal from the
judgment of conviction rendered by this court and appeals to the Court of
Appeals of the Philippines.

Panabo City, Philippines, August, 2016.

Lionel A. Messi
Counsel for the Defendant
Public Attorney’s Office
Rm. B-29 Hall of Justice, Panabo City
Until December 31, 2016
Roll of Attorney’s No.
PTR No.
IBP No.
MCLE No.

COPY FURNISHED:

ATTY. DANIEL CARVAJAL


Counsel for the Plaintiff
Purok 6B, Brgy. Lakandula
Panabo City, Dav Nor
REPUBLIC OF THE PHILIPPINES
REGIONAL TRIAL COURT
11TH JUDICIAL REGION
PANABO CITY
BRANCH 1

MANG KANOR,
Accused-Appellant,

- versus CA-GR. No. 12345


For: Acts of Lasciviousness

PEOPLE OF THE PHILIPPINES,


Plaintiff-Appellee.
x-------------------------------------x

BRIEF FOR APPELLANT

Accused-Appellant, by counsel, and to this Honorable Court


respectfully files his brief for the appellant.

PREFATORY STATEMENT

An obvious violation and disregard of the right to due process


was committed against the defendant-Appellant in this case.

The Honorable Court in its decision dated on October 15 2016


find for the Plaintiff-Appellee based on mere allegations not supported
by evidence sufficient to draw a conclusion so as to comply with Sec.
14, Article VIII of the constitution.

The Honorable Supreme Court on this premise made


pronouncement in a case brought forth, thus:

“The court finds occasion to remind courts


and quasi-judicial bodies that “[a] decision
should faithfully comply with Section 14,
Article VIII of the Constitution which provides
that no decision shall be rendered by any court
[or quasi-judicial body] without expressing
therein clearly and distinctly the facts of the
case and the law on which it is based…. It is a
requirement of due process and fair play that the
parties to a litigation be informed of how it was
decided, with an explanation of the factual and
legal reasons that led to the conclusions of the
court [or quasi-judicial body]. A decision that
does not clearly and distinctly state the facts and
law on which it is based leaves the parties in the
dark as to how it was reached and is especially
prejudicial to the losing party, who is unable to
pinpoint the possible errors of the court [or
quasi-judicial body] for review by a higher
tribunal.1

THE PARTIES

MANG KANOR is the appellant as represented by LIONEL A. MESSI,


PAO, Panabo City where process and notice from this court may be
served at room B-29, Public Attorney’s Office, Hall of Justice, Panabo
City while THE PEOPLE of the PHILIPPINES is the appelle as
represented by the Panabo City Prosecutors Office

TIMELINESS OF THE APPEAL

Accused-appellant received on October 18, 2016 the Decision of the


Municipal Circuit Trial Court dated October 15, 2016. A Notice of
Appeal was timely filed on July 20 2002. Accused received on October
25, 2016 the Order from the Regional Trial Court directing him to file
his Appeal Brief within fifteen (15) days from receipt. Hence ,this
timely compliance.

I
STATEMENT OF FACTS

l.1 MANG KANOR is a forty (40) years old man who works as a
government employee in the Local Government of Nabunturan as a
means of livelihood. The private complainant, Aling Moana is a an
employee of Davao Doctors Hospital;
1.2 Private complainant alleged that she was sexually molested by her
ex-boyfriend, accused-appellant in the instant case in the evening of
December 23, 2015 inside the passenger van bound for Tagum City;

1.3 The passenger van was traversing the highway of Panabo City in
that evening. The van had a cabin light and there were few passengers
on board the said van where the offense charged was allegedly
committed by the accused-appellant;

1.4 On the dates of the alleged commission of the offense charged, the
accused-appellant was travelling going to his home in Nabunturan,
ComVal Province;

1.5 It was reported that the accused-appellant was drunk when he


alighted the passenger van as alleged by the private complainant and her
lone witness;

II
ASSIGNMENT OF ERRORS

The municipal court committed the following errors:

1. The prosecution’s evidence is insufficient to prove


the guilt of the accused-appellant beyond reasonable
doubt;

2. The Trial court erred on imposing the additional


penalty of civil indemnity and moral damages that is
not supported by law and the facts alleged by
appellee.

III
ARGUMENTS

1. The prosecution’s evidence is


insufficient to prove the guilt of the
accused-appellant beyond reasonable
doubt;

It is the Constitutional right of the appellant that


“every circumstance favoring the innocence of the accused must
be duly taken into account. The proof against him must survive
the test of reason” (Duran vs. Court of Appeals, 71 SCRA 68).
Thus it is the sole duty of the prosecution to present evidence
sufficient to prove the accused guilt beyond reasonable doubt.
The evidence presented by the prosecution however in this case, is
insufficient and has been clearly rebutted by countervailing proof
by appellant. The following facts are presented by appellant to
this honorable court which the lower court has failed to take
credence.

a. Delay in Filing Complaint Renders the Act of


Lasciviousness Charge Doubtful.

The alleged rape was committed on December 23, 2015,


however, the appellant was arraigned only on January 30,
2016. Charges was only formally filed a month after. Her
affidavit was only executed on January 24, 2016 (Exhibit “A”).
This creates much doubt as to the claim of the alleged victim.
The Supreme Court has already ruled that the “delay in filing
criminal proceedings for acts of lasciviousness may result in
adverse inference against the complainant”.

b. Incredible.

With the presence of some passengers, driver, and


conductor, the alleged acts of lasciviousness was
consummated on the back seat of the driver inside the
passenger van while the cabin light is on, the opportunity to
commit the acts of lasciviousness is hardly present. The
testimony of the conductor is not well founded as he was
looking outside the van calling for a prospect passenger. It
is that he saw the alleged malicious act while looking for
passengers outside the van.

c. Long Silence Runs Counter to Natural Reaction.

Despite the availability of resources to speak to, the


victim slept on her rights on reporting the alleged acts of
lasciviousness. “Needless to state, such conduct runs
counter to the natural reaction of an outraged maiden
despoiled of her honor xxx. In fine, the complainant’s
testimony in the instant case lacks that stamp of absolute
truth and candor necessary to overcome the constitutional
presumption of innocence.” (People vs. Romero, Jr., 117
SCRA 897).

d. Absence of attempt to ask for help.


The absence of any action on the part of the victim to
call for help or shout for assistance taking into
consideration the allegedly act of lasciviousness were
committed inside a passenger van, which van was also full
of passengers, runs much doubt as to the credibility of the
commission of the offense and against the basic norms of a
girl of good repute.

e. Sole assertion of the alleged victim is not more than enough


to over turn the burden of proof to prove the accused guilt.

The Royeras ruling as stated in the trial court’s decision,


does not apply in the case at bar, for the facts previously
stated has created more than sufficient contrary proof, to
allow reversal of the trial court’s ruling.

2. The Trial court erred on imposing the


additional penalty of civil indemnity
and moral damages that is not
supported by law and the facts alleged
by appellee.

The trial court failed to consider the following articles:

a. Article 2234 of the Civil Code provides “that the plaintiff


must show that he is entitled to more xxx damages xxx
before the court may consider xxx.”
b. Article 66 of the Revised Penal Code provides: “In imposing
fines the courts may fix any amount within the limits
established by law xxx, but more particularly to the wealth
or means of the culprit.”

The municipal trial court awarded moral damages on the act of


lasciviousness not established beyond reasonable doubt. This award
was rendered without being alleged, proved and prayed by the appelle.
Damages are never presumed but must be proven by competent
evidence, which the prosecution has failed to do. Also the trial court
imposed a civil indemnity on both counts, failing to consider the fact
that the accused is a 40 year old man whose main source of income is
being a lowly government employee. Thus the awards are both contrary
to law and from the basic norms of fair play and equity.

PRAYER

WHEREFORE, the accused-appellant respectfully prays that


Decisions of the municipal trial court be reversed, set aside and
nullified, and the judgment be rendered in favor of the accused-
appellant as prayed for in his answer; to dismiss the two counts of rape
for his guilt has not been proven beyond reasonable doubt.

Accused-appellant further prays for such other relief as may be


just and equitable in the premises.

October 27, 2016.

ATTY. LIONEL A. MESSI


Counsel for Accused-Appellant
IBP Lifetime NO. 05672
Roll No. 56123
MCLE II Compliance No. 0003743
Public Attorney’s Office
Rm. B-29 Hall of Justice, Panabo City

VERIFICATION/CERTIFICATION

I, MANG KANOR, of legal age, Filipino and a resident of


Nabunturan, Compostela Valley Province after having been
duly sworn to in accordance with law, do hereby depose and
say:

l. I am the accused-appellant in the foregoing Brief;

2.I caused the preparation of the foregoing pleading;

3. I have read the same and the allegations therein are true and
correct of my personal knowledge or based on authentic
records.

4. I have not commenced any other action involving the same


issues in the Supreme Court or different divisions thereof or
any other tribunal or agency.

IN WITNESS WHEREOF, I have affixed my signature this


day of October 25, 2016 at Panabo City.
MANG KANOR

SUBSCRIBED AND SWORN to before me this 25 th day of


October 2016 at Panabo City,Philippines. Affiant exhibited to me his
Community Tax Certificate No. CC 123456 issued at Nabunturan,
Compostela Valley Province.

Atty.Luis B. Suarez
Notary Public
Notarial Commission until Dec 30,2016
PTR NO. 023456/01/05/10/ Panabo

Doc. No.: 39
Page no.:8
Book no.:I
Series of 2016

Copy Furnished:
Office of the Provincial Prosecutor
Panabo City Davao del Norte

EXPLANATION

Pursuant to Section II, Rule 13 of the 1997 Rules of Court, the


foregoing Brief is sent by registered mail due to lack of messengerial
personnel and time constraint in the filling thereof.

LIONEL A. MESSI

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