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Republic of the PhilippinesREGIONAL TRIAL COURT
First Judicial RegionBranch _____Baguio City
JOEY D, Civil Case No ________Petitioner. For:
-versus- Declaration of Nullity of Marriage
JENNY H.,Respondent,
x-------------------------------------------------x
FORMAL OFFER OF EVIDENCEFOR THE PETITIONER
WITH ALL DUE RESPECT
PETIOTIONER, through the law firm and unto the Honorable Court respectfully submits their formal offer of Documentary Exhibits, to wit:
EXHIBIT “A” Marriage Certificate between Petitioner and RespondentEXHIBIT “B” Birth Certificates of the Jacob D, Johnson D, and Julia DEXHIBIT “F” Certificate of Non-Property
PURPOSES: These documents are being offered to form part of the testimony of the petitioner and to prove that the parties contracted marriage, that out of their union they begot three children and during their marriage, no real property was acquired by them.
EXHIBIT “H” Judicial Affidavit of Joey DEXHIBIT “H-1” Signature of Joey DEXHIBIT “I” Judicial Affidavit of Sherborn CalsiyaoEXHBIT “I-1” Signature of Sherborn CalsiyaoEXHBITS “J” Judicial affidavit of Pedro “Pedring” Emperador,
PURPOSES: These is being offered to corroborate the testimony and petition for declaration of nullity of marriage of petitioner and to prove respondent’s inability and incapacity to fulfil the marital obligation of fidelity to the petitioner , rendering mutual support and the obligation of living together
EXHBIT “E” Curriculum Vitae of Dr. Fhely Layogan EXHIBIT“E-1”and “E-2” Pscychological Examination Report
conducted by Dr. Fhely Layogan on Petitioner and Respondent to prove that she is suffering from “That from Histrionic Personality Disorder coupled with Dependent Personality Disorder and as such;”
EXHIBIT “E-3” Judicial Affidavit of Dr. Fhely Layogan, to testify that Petitioner is suffering from “Dependent Personslity Disorder coupled with Histrionic Personality Disorder” which is tantamount to psychological incapacity as written in a psychological evaluation report conducted on the respondent on December 26, 27, and 28 2014
EXHIBIT “E-3” Signature of Dr. Fhely Layogan, psychologist
PURPOSES: These are being offered as part of the testimony of Dr. Fhely Layogan, the psychologist who conducted the psychological evaluation. These are likewise bwing offered to prove that after the study, it was found out that the respondent is psychologically incapacitated to comply with the respective marital obligations of the spouses embodied in the Family Code, the precise cause thereof is the personality disorder of the respondent. That said psychological incapacity on the part of the respondent is grave, incurable and with juridical antecedence, and had existed before and during the marriage
Respectfully Submitted:April 14, 2015 at Baguio City,Philippines
LK LAW FIRMSuite 204, Puso ng BaguioSession Road, Baguio City
By:
DIAMOND SUPNET KELSCHIBP: 994543, 2/17/13, Baguio City
PTR No. 23434, 1/16/13; Baguio CityRoll No. 34534, 4/8/12; Manila
MCLE Compliance No. IV-443456, 7/7/14; Baguio CityTelefax No. (074) 442 -3495-08653, Mobile no. 09173435235
LAUREL LIMNMAYOGIBP: 99434543, 2/17/12, Baguio CityPTR No. 23434, 1/16/12; Baguio City
Roll No. 34534, 4/8/11; ManilaMCLE Compliance No. IV-45546, 7/7/14; Baguio City
Telefax No. (074) 442 -3495-08653, Mobile no. 09394354456
Copy furnished:
BUENVENIDA-SANTOS AND ASSOCIATES Counsel for the RespondentUnit 15 Deleon Bldg.Session Road, Baguio City2600 Philippines
CLERK OF COURTRTC BRANCH 4BAGUIO CITY
Please submit the foregoing Gormal offer of Rvidence immediately upon receipt hereof for the kind consideration of the Honorable Court
Thank you
DIAMOND S. KELSCH
COPY FURNISHED:
OFFICE OF THE CITY PROSECUTOR (by personal service)BAGUIO CITY, BENGUET