Republic of the Philippines

REGIONAL TRIAL COURT

Ninth Judicial Region
Branch 22
Pagadian City
-oOo-

ANALIZA RODA-GULOY, CIVIL CASE NO. 5021-2K13

Petitioner,

-versus- -for-

BANIE O. GULOY, JUDICIAL DECLARATION OF

Defendant. NULLITY OF MARRIAGE
X------------------------------------------/

FORMAL OFFER OF
DOCUMENTARY EXHIBITS

Petitioner, through undersigned counsel, unto the Honorable Court, respectfully

submits this Formal Offer of Documentary Exhibits, viz:

Exhibit “A”- the Marriage Contract between Banie O. Guloy and Analiza C. Roda ;

Purpose/s: To prove that plaintiff and defendant are married to each other;

Exhibit “B”- the Certificate of Live Birth of Rannie R. Guloy; and

Exhibit “C”- the Certificate of Live Birth of Rodil R. Guloy;

Purpose/s: To prove the filiation of the children born during the marriage
of Banie O. Guloy and Analiza C. Roda;

Exhibit “D”- Standard Employment Contract for Filipino Household Service Workers of
Analiza R. Guloy;

Purpose/s: To prove that Analiza R. Guloy has employment abroad,

hence the necessity of taking her deposition pending action;

Exhibit “E”- Airline Ticket of Analiza R. Guloy;

Purpose/s: To prove that Analiza R. Guloy has to leave the country

before her action could commence its trial, hence the
necessity of taking her deposition pending action;

Exhibit “F”-Visa of Analiza R. Guloy;

Purpose/s: To prove that the travel of Analiza R. Guloy abroad is lawful

and valid;

Exhibit “G”- the report of Acting City Prosecutor Celso D. Manuales;

Purpose/s: To prove that the handling prosecutor found out no evidence

of collusion between the parties;

Exhibit “H”- Psychological Evaluation Report of Ruby Jane Tugade;

Purpose/s: To prove that a psychological evaluation was conducted by

an expert witness on the parties;
 To prove that defendant is suffering from a psychological disorder known
as Antisocial Personality Disorder, which rendered her incapable of
fulfilling her essential marital obligations; and,

To prove that the psychological incapacity suffered by the defendant

already existed prior to the marriage, it so grave, and that the same is
incurable, thus rendering defendant incapable of fulfilling her essential
marital obligations to the plaintiff;

Exhibit “I”- Transcript of stenographic notes of the deposition taking of the pliantiff;

Purpose/s: To prove that indeed the testimony of the deponent-plaintiff

was taken before the deposition officer appointed by the
court;

WHEREFORE, It is prayed that all the foregoing exhibits, in addition to

the direct testimony via judicial affidavits of plaintiff and his witnesses, be
admitted as part of the evidence of the plaintiff.

With the formal offer of all the foregoing exhibits, the Plaintiff most
respectfully rests its case.

Respectfully submitted this ____ day of November 2014 at Pagadian City,

Philippines.

ATTY. FELIX M. ESCALANTE, JR.

Counsel for Plaintiff
Provincial Capitol Complex
Pagadian City
Attorneys Roll No. 57655
IBP No. 857744 2/18/2014
Issued at Pagadian City
PTR No. 7885184 2/18/2014
Issued at Pagadian City
MCLE COMPLIANCE IV-0014312
Issued on March 21, 2013
Email ad: pgochief@yahoo.com
0917-623-0775

Copy furnished:

The Solicitor General, thru

The City Prosecutor
Justice Hall
Pagadian City
ATTY. FELIX M. ESCALANTE, JR.
Counsel for Plaintiff
Provincial Capitol Complex
Pagadian City
Attorneys Roll No. 57655
IBP No. 963359 1/6/2015
Issued at Pagadian City
PTR No. 8536180 1/7/2015
Issued at Pagadian City
MCLE COMPLIANCE IV-0014312
Issued on March 21, 2013
Email ad: pgochief@yahoo.com
0917-623-0775