Petitioner, through the undersigned counsel, unto this
Honorable Court, most respectfully offers the following pieces of evidence, to wit:
Exhibit A Certificate of Marriage
Purpose: To prove that there is valid and existing marriage
between the petitioner and the respondent.
Exhibit B Certificate of Live Birth of Carl Jam Dela
Cruz Duruin
Exhibit C Certificate of Live Birth of Lance Ashley
Dela Cruz Duruin Purpose: To prove the facts of birth of Carl John and Lance Ashley and the existence of their respective Certificate of Live Birth.
Exhibit D Psychiatric Evaluation Report
Purpose: To prove that there is a condition of psychological
incapacity on the part of the respondent which prevents him from performing his duties and responsibilities as husband to the petitioner.
Exhibit E Judicial Affidavit of Alona P. Duruin Dated
August 2017
Purpose: To prove the allegations in the said Judicial
Affidavit.
Exhibit E-1 Signature of Alona P. Duruin in her Judicial
Affidavit
Purpose: To prove that the statements made by Alona P.
Duruin are true and correct.
Exhibit F Personal Information of Dr. Ethel Maureen
Biscaro-Pagaddu
Purpose: To prove that Dr. Pagaddu is qualified to conduct
Psychiatric Evaluation over the person of the petitioner and the respondent.
Exhibit Signature of Dr. Ethel Maureen Biscaro-
Pagaddu
Purpose: To prove that a clinical identification of the root
causes, antecedence, gravity and incurability of the psychological incapacity of respondent to perform his essential marital obligations has been made and that it was found that this is in the form of a mental disorder considered to be grave, severe, long lasting and incurable by any treatment available. These are also being offered as part of the direct testimony of the expert witness.
RESPECTFULLY SUBMITTED.
WHEREFORE, it is most respectfully prayed unto this
Honorable Court that the above-mentioned pieces of evidence be ADMITTED.
Other just and equitable reliefs are also prayed for.
February 19,2018,
ATTY. CONCEPCION N. SAMONTE
Counsel for the Petitioner Rizal Street, Lumban, Laguna PTR No. 1651829/1-2-14 IBP Roll No. 941655/11-6-13 MCLE Compliance 907446