CASE:

COURT:
BRANCH:
NATURE:

 Complaint (with Judicial Affidavit)

 Use the new certificate against forum shopping and verification
 Service of summons (Court)
 Motion (if necessary)
 Answer
 Reply (only if there is actionable document)
 JDR
 Pre-trial
 Trial
 Presentation of complainant’s witnesses
 Cross, redirect, recross
 Presentation of Defendant’s witnesses
 Cross, redirect, recross
 The case will be submitted for decision
 Formal offer of evidence
 Decision
 Entry of Judgment
 Writ of execution

 If despite valid service of summons, the defendant did not appear, a

motion to render summary judgment may be moved.

 If the case is dismissed due to failure to serve summons, file an MR with

prayer to issue an alias summons anew.

 For cases subject to summary proceeding, what may not be subject to

Motion for Reconsideration is the judgment and not the interlocutory
order.

 The Judgment may subject to Certiorari

 For regular cases, if the decision is not in favor, MR must be filed.

How to cross examine?

1. Be brief. Short questions with simple words

Why? Because it will be retained by the listeners
2. Plain words
3. Leading questions are allowed, so maximize it.
4. Cross examination is not a deposition, it is not a discovery. If you do not
know the answer, do not ask it. If the witness answers no, you must be ready
to have a follow up question.
Xpn: if you do not care of the answer
5. Listen to the witnesses’ answers. In order to determine when there is an
unexpectedly favorably answer, and in order to prepare a responsive
question.
6. Don’t quarrel with the witness.
If the answer is contrary to the law, sit up and that is the time to
stop. Save it for summation. Because if you are going to quarrel with
the witness, he will realize that he did something wrong and explain the
same.

7. “There are couples of things about your direct that are unclear, let us clear
them up” “What are ___?” “are you sure?” - DON’T LET THE WITNESS
REPEAT.
8. Don’t permit the witness to explain anything. The questions are entirely
leading questions. Don’t let the witness qualify.
9. You ask question only to get to support your summation
10. Summation (goal is to satisfy the judge’s curiosity)