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REPUBLIC OF THE PHILIPPINES

FOURTH JUDICIAL REGION


REGIONAL TRIAL COURT
BRANCH 72, ANTIPOLO CITY
PEOPLE OF THE PHILIPPINES,
Complainant,

CRIM. CASE Nos. 09-3834038342


For: Child Abuse
in relation to R.A. 7610

-versusAMANTE LARITA
Respondent.
x----------------------------------------x
Witness: DR. JOSEPH MAURO B. SAYO, MD. DPBP, psychiatrist of private
complainant.
Offer:
1. To prove that private complainant was evaluated as a victim of sexual
abuse;
2. To prove moral and exemplary damages;
3. To identify his Psychiatric Evaluation Report (to be marked in open
court);
4. To identify other documents relevant and material to the case;
5. Other matters which may be relevant and material to the case.
Questions:
I.

Preliminary Questions Qualifying the Expert Witness

1. What is your profession?


2. Can you please give us a summary of your educational background to
become a psychiatrist?
3. What certifications or licenses do you have?
4. Have you attended postgraduate courses and continuing education
seminars or trainings? Can you enumerate them?
5. Are you a member of any professional organizations or societies?
Please state them.
6. Have you published research articles in your field?
7. What hospitals are you affiliated with?
8. You mentioned PGH, are there non-hospital affiliations that you are
involved with?

9. What are your areas of specialization as a psychiatrist? What is child


psychiatry?
10.
What was required of you to become specialized as a child
psychiatrist?
11.
Can you explain to us the difference between a psychologist and
a psychiatrist?
12.
How many other child psychiatrists in the Philippines are
diplomates in the Philippine Board of Psychiatry?
13.
How many years of professional experience have you spent
working with children who were sexually abused?
14.

How many cases involving child sexual abuse have you handled?

15.
What are the criteria you use to decide whether or not to take a
case?
16.
Have you ever testified as an expert witness for a case involving
child sexual abuse? How many times?
II.

Need for Expert Opinion

17.
This case involves a child who is an alleged victim of sexual
abuse. What are the matters about sexual abuse that require an
expert to explain?
18.
What are the key principles that a person without education or
experience in this field would need to grasp in order to understand
this case?
19.
What are the behavioral characteristics of a victim of sexual
abuse usually exhibit?
20.
How would the testimony of an expert witness aid the judge in
understanding the facts in this case?
III.

Basis for Expert Opinion and Psychiatric Evaluation Report

21.
Dr. Sayo, can you please tell the Court if you reviewed the
psychiatric records of the child in the custody of the CPU-PGH?
22.

What date was the previous psychiatric examination?

23.
The said ___ (Please enter date of examination) examination was
conducted by one of your subordinates, is that correct? So, as the
psychiatrist with a supervisory role, you were also privy to the
contents of the said psychiatric examination?
24.
While you were working at CPU-PGH, have you come across a
person by the name of RHOCES GRACE HERMOGENO, the private
complainant in this case?

25.

When and where did your psychiatric evaluation take place?

26.
What tests do you use to determine the veracity of the claim of a
victim of child abuse? (i.e objective case; diagnostic questionnaires)
27.

What can you conclude about the reliability of these tests?

28.
Prior to consultation with you, what disclosure, if any, did
RHOCES GRACE HERMOGENO personally tell you about certain
incidents that happened to her.
29.
During the course of interviewing RHOCES GRACE
HERMOGENO, what did you learn about her family, if any?
30.
What kind of traumatic symptoms did she manifest that were
consistent with her report of abuse?

31.
According to your psychiatric evaluation of RHOCES GRACE,
were there other members of the family who witnessed the abuse?
Who were these?
32.
What sort of behavioral changes manifested in RHOCES GRACE
after the incidents of abuse?
33.

What else, if any?

34.
I am showing to you the Transcript of Filipina Hermogeno, the
grandmother of RHOCES GRACE during her Direct Examination
wherein she mentioned her observation of RHOCES GRACEs change
of behavior, specifically the change in her gender preference. Based
on your experience, what are the usual causes of this change of
behavior?
35.
What was the disposition of RHOCES GRACE when she was
being questioned about the abuse?
36.
How come there are victims who shy away from re-telling their
sexual abuse experience? What could justify RHOCES GRACEs
cooperativeness during the evaluation?
37.
What kind of disorder would RHOCES GRACE possibly manifest,
if any?
38.

What kind of therapy was recommended to her?

39.

What is psychotherapy?

40.
Based on your education and extensive professional experience,
have you made a diagnosis or formed a psychiatric opinion regarding
the cause of RHOCES GRACEs traumatic symptoms you previously
discussed?
41.
Was the psychiatric opinion you mentioned earlier embodied in
a psychological evaluation report?
42.
If I show you a copy of this Psychological Evaluation Report,
would you be able to identify it? (Ask witness to identify Psychological
Evaluation Report, his own signature and license number)
43.
Within your field of specialization, is it common for a
practitioner to give an opinion as to the traumatic symptoms and
disorders in the evaluation of a victim of sexual abuse?
44.
How is this opinion relevant to an assessment of whether or not
a child suffering traumatic symptoms was a victim of sexual abuse?
45.
What facts or evidence did you rely on in formulating your
opinion?
46.
What type of evidence are relied on in the ordinary course by
professionals in your field? (establish that the same evidence are
being relied on)
47.
What other evidence are relied on in the ordinary course by
professionals in your field as part of making such a determination that
you did NOT use? Why not?
48.
To your knowledge, were there any other experts who also
examined RHOCES GRACE or administered psychotherapy or
counseling to her? Who?

Thank you, Dr. Sayo.


Your honor, may I request the honorable Court to have this
Psychological Evaluation Report marked as EXHIBIT ___ and the
signature of Dr. Joseph Sayo as EXHIBIT __ - 1, and made an integral
part of the records of the case.
That is all for the witness, Your Honor. Thank you.