3/30/2021
E-Library - Information At Your Fingertips: Printer Friendly
WITH DUE RESPECT, THE LOWER COURT ERRED IN IGNORING THAT WHEN
SPO2 [sic] EILE[E]N FERMINDOZA ENTERED THE RESIDENCE OF JASMIN[E]
ALEJANDRO, THERE WAS NO CRIME COMMITTED WHATSOEVER, HENCE THE
ARREST OF THE ACCUSED-APPELLANT WAS ILLEGAL;
[IV]
WITH DUE RESPECT, THE LOWER COURT ERRED IN NOT DISCOVERING
THAT SPO2 [sic] EILE[E]N FERMINDOZA WAS NOT ILLEGALLY RECRUITED
BY THE ACCUSED-APPELLANT, HENCE, ACCUSED-APPELLANT SHOULD BE
ACQUITTED;
V
WITH DUE RESPECT, THE LOWER COURT ERRED IN NOT DETECTING THAT
NANCY ARANETA WAS NOT ILLEGALLY RECRUITED BY THE ACCUSEDAPPELLANT, HENCE, ACCUSED SHOULD BE EXONERATED;
VI
WITH DUE RESPECT, THE LOWER COURT ERRED IN NOT REALIZING THAT
MARIA LOURDES MODESTO WAS NOT ILLEGALLY RECRUITED BY THE
ACCUSED-APPELLANT,
HENCE,
ACCUSED-APPELLANT
SHOULD
BE
EXCULPATED;
VII
WITH DUE RESPECT, THE LOWER COURT ERRED IN FINDING THAT THE
ACCUSED-APPELLANT WAS CHARGED WITH LARGE SCALE ILLEGAL
RECRUITMENT ON JANUARY 30, 1994, THE DATE STATED IN THE
INFORMATION AS THE DATE OF THE CRIME, BUT ACCUSED WAS ARRESTED
ON FEB. 2, 1994 AND ALL THE EVIDENCES [sic] INDICATED [sic] THAT THE
ALLEGED CRIME WERE [sic] COMMITTED ON FEB. 2, 1994, HENCE, THE
INFORMATION IS FATALLY DEFECTIVE;
VIII
WITH DUE RESPECT, THE LOWER COURT ERRED IN NOT FINDING THAT THE
ALLEGED CRIME OF ILLEGAL RECRUITMENT WAS COMMITTED NOT ON [sic]
LARGE SCALE, HENCE, THE PENALTY SHOULD NOT BE LIFE IMPRISONMENT;
IX
WITH DUE RESPECT, THE LOWER COURT ERRED IN NOT FINDING THAT
THOSE EVIDENCES [sic] SEIZED AT THE HOUSE OF JASMIN[E] ALEJANDRO
AND PRESENTED TO THE COURT WERE PLANTED BY A BOGUS ATTORNEY[,]
ERLIE S. RAMOS OF THE POEA;
https://elibrary.judiciary.gov.ph/thebookshelf/showdocsfriendly/1/49893
7/20