Republic of the Philippines

Regional Trial Court

MLQU Branch 201

Josepha D. Estrella
Petitioner

-versus Civil case no. 12345

For: Annulment of Marriage

Grace Ragsag Estrella

Respondent
x-------------------------x
Republic of the Philippines)
Quezon City ) S.S.

PETITIONER’S PRE TRIAL-BRIEF

Petitioner, by the undersigned counsel, unto the Honorable court,

most respectfully submits his pre-trial brief, to wit:

I. Issues

1. Whether or not respondent is suffering from psychological

incapacity which would warrant the annulment of marriage.

2. Whether or not such incapacity existed before, after and during

the marriage.

3. Whether or not such incapacity is incurable.

II. Witnesses

1. Plaintiff-to prove the facts alleged in the petition

2. Psychologist Chrystal Abelgas-to testify that respondent is

suffering from psychological incapacity.

3. Manny Collado-brother in law of petitioner, to corroborate the

testimony of the petitioner.

 4. Shiela Boquiron-daughter of both petitioner and respondent, to

disprove the testimony of the petitioner.

5. Grace Estrella-wife of the petitioner, to disprove the facts

alleged by the petitioenr

III. Documentary evidence

Exhibit A- A copy of the Marriage Contract of petitioner and

respondent.

Exhibit B-birth certificate of Sheila Boquiron

Exhibit C-birth certificate of Marven Kenneth Estrella

Exhibit D-birth certificate of Lorilyn Katrine Estrella

Exhibit E-psychological report of the psychologist

The petitioner reserves the right to present other documents not

herein listed as may be deemed necessary.

IV. Trial Dates

To be set during the pre-trial proper.

RESPECTFULLY SUBMITTED.

Paulo Rommel Y. Camanian

Counsel for the Petitioner

Copy furnished:

Joshua G. Maquiling
Counsel for the Respondent