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Sixth Judicial Region
Branch _______
CJ Ramon Q. Avancena Hall of Justice
Iloilo City


Civil Case No. __________
For: Declaration of Nullity of

PETITIONER, by counsel, respectfully submits his Pre-Trial
Brief, as follows:
1.1. Subject to a concrete proposal that is fair and
reasonable and a reciprocal manifestation of openness from
respondent, defendant is open to the possibility of amicably settling
this dispute.

2. even going as far as placing a downpayment on a duplex in Brgy. 2. 3 of respondent’s answer and avers that it was he who was persistent in finding ways to live away from respondent’s parents. Pag-ibig and SSS benefits to defray . Iloilo City but respondent simply refused to part from her parents.1. Negros Oriental.4. 4 of respondent’s answer. 5 of respondent’s answer. Petitioner seeks to annul the marriage under Article 36 of the Family Code.II. he immediately calls respondent.3. and avers that he utilized his Philhealth. BRIEF STATEMENT OF CLAIMS AND DEFENSES 2. but avers that his failure to communicate with her during his visits to his parents was due to the lack of telecommunications signal in Bacong. Petitioner denies Par. Petitioner concedes the truth and veracity of Par. and that the moment the signal has returned.2. on the ground of psychological incapacity on the part of respondent. a far-flung barrio which can only be accessed through single motorcycle. 2. Tanza. Petitioner denies the Par. City Proper.

Iloilo but only on weekends. 6 of respondent’s answer.7. In addition.respondent’s delivery expenses. 2. petitioner avers that he had been solely responsible for the care and upbringing of their common son. 2. ..6.” not diagnostic sessions. He was diagnosed to have no mental illness by Dr. 7 of respondent’s answer but avers that he was informed that he will be attending “marriage counseling. Leouel Jr. Petitioner partially concedes the truth and veracity of Par. and avers that he gives a portion to respondent as his contribution for household expenses while the rest he deposits in a savings and investment fund with AXA Philippines. 2. Petitioner concedes the truth and veracity of Par. Petitioner denies Par. and that his free time is mainly spent target shooting in Guimbal. Daisy ChuaDaquilanea. a clinical psychiatrist.5. 10 of respondent’s answer but avers that he desired a second opinion.

1987. That their married life was marred with frequent quarrels due to the frequent interference by respondent’s parents into the spouses’ family affairs and over a number of other things. like when and where the couple should start living independently from the respondent’s parents or whenever the respondent would express resentment on the petitioner’s spending a few days with his own parents..1. 3. they exchanged vows before Municipal Trial Court Judge Cornelio G. FACTS AND OTHER MATTERS ADMITTED BY THE PARTIES 3. 3. 3. That on July 18. Lazaro of Iloilo City. 3. La Paz. Jr.4. That petitioner Leouel Santos and respondent Julia Rosario Bedia-Santos first met in Iloilo City where the former held the rank of First Lieutenant in the Philippine Army. Bedia Compound.5. The parties lived with the latter's parents at the J.2. Iloilo City.III. .3. the respondent gave birth to a baby boy who was christened Leouel Santos. 1986. That on September 20.

1. That on May 18.2.1. 1988. ISSUES TO BE TRIED 4. the respondent called up the petitioner for the first time by long distance telephone. let alone appear.3. . That the only contact they have had since respondent departed for the United States was in connection with the case at bar.7. Leouel Jr. 3. That seven months after her departure. 3. or on January 1. She never did. the respondent left for the United States of America to work as a nurse despite the petitioner’s pleas to so dissuade her. 1989.Whether respondent’s failure to communicate.8.1.1. Petitioner submits that the following issues he put forward are subject to proof: 4. is likewise an indicum of psychological incapacity. IV. 4. during the entire duration of her stint abroad is an indicum of psychological incapacity. She promised to return home upon the expiration of her contract in July 1989.6.Whether respondent’s indifference to the welfare of their son.

Ma.1. which was controverted by a second opinion from Dr. Petitioner submits that the following issues put forward by the respondent are subject to proof: 4. to establish that petitioner has often requested for certifications pertaining to his Philhealth.1.1. including but not limited to his delivery and various sicknesses while growing up. has any proximate relation to the issue of his supposed psychological incapacity. to establish the absence of mental illness on the part of petitioner. Geralyn Gabriel. Daisy-Chua Daquilanea.. Daisy Chua-Daquilanea. Petitioner intends to present the following witnesses: 5. Pag-Ibig and SSS benefits for expenses incurred in connected to Leouel Jr. .1. Dr. Ma. V. Whether the diagnosis of Dr. EVIDENCE 5.2. Administrative Officer IV. Lourdes Go that petitioner is afflicted with Shcnauber Schizophrenia.2.

) to present. Jr. Mona Liza M. 1987 (birth of Leouel. neighbor of petitioner in Brgy. father of respondent.2.1. Ceril Lyn L.2. Sambag.1. Iloilo City. to establish how petitioner brought up Leouel Jr.5. Petitioner intends to present the following documentary evidence: 5. Jose Bedia. 5.4.2. Burro.1.2. . 1987 (birth of Leouel.3. 5. 5. 5. Jaro. to establish that even with her parents the respondent has not appeared or sent any message whatsoever. 1987 (birth of Leouel. His Pag-Ibig contribution record from July 18. Gestoso.3.2. His SSS contribution record from July 18.’s tuition and other school fees.) to present. Jr. Jr.5. in the absence of respondent. Iloilo to establish that it was petitioner who personally paid Leouel Jr. Accounting Officer of Gamot Cogon International School in Zarraga.) to present. 5.1. His Philhealth contribution record from July 18.

.5. RESPECTFULLY SUBMITTED. The receipts for tution and other school expenses of Leouel Jr. however. The telephone bills amassed by petitioner in his fruitless search for respondent. petitioner reserves the right to resort to discovery before trial. 2015. VII. November 28. December 2015 to February 2016. at any day convenient. VI. Subject. Respondent does not intend to avail of discovery at this time. Considering the relatively simple issues presented. b. 5. Iloilo City.5.4. Resort to Discovery a. to a concrete and reasonable request for discovery from respondent.2. Available Trial Dates a.2.

01/10/10-Manila Ptr No. 123456. X Building Recto Manila IBP No. 12345. ACE MACALALAG Counsel for the Defendant Co-Counsel for the Defendant MacDo Law Office Unit 1.BEVERLY JANE H.5/05/05 MCLE No.01/10/10-Manila Roll No.01/10/10-Manila Roll No. PETRI JOHN L. 1-001234. 123456. 1-001234. 30724 MCLE Compliance No.9/09/15 . BULANDAY Counsel for Petitioner IBP # 605482 1/8/15 Iloilo City PTR # 0417576 1/8/15 Iloilo City Roll of Attorneys No.5/05/05 MCLE No.01/10/10-Manila Ptr No.1234567.1234567. II 01-23455 Copy furnished: ATTY. 12345. DORONILA Lead Counsel for the Defendant MacDo Law Office Unit 1.9/09/15 ATTY. X Building Recto Manila IBP No.