Exhibit H

REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION
REGIONAL TRIAL COURT
FAMILY COURT
MAKATI CITY

MARIA CLARA DE LOS SANTOS-

IBARRA, Civil Case No. 12345

Petitioner, For: Petition for

Annulment
-versus-
CRISOSTOMO MAGSALIN
IBARRA,
Respondent.

JUDICIAL AFFIDAVIT
MARIA CLARA DE LOS SANTOS-IBARRA

This Judicial Affidavit of MARIA CLARA DE LOS SANTOS-

IBARRA is executed to serve as her testimony in relation to the trial
of the instant case. This Judicial Affidavit is offered to prove:
1. That respondent, Crisostomo Ibarra is married to Maria Clara
delos Santos – Ibarra.

2. That after marriage, Maria Clara delos Santos-Ibarra

contracted a sexually transmitted disease from the
respondent.

3. That the affiant found out that her husband, the respondent,
engaged in a homosexual relationship prior to and during
their marriage.

4. That respondent concealed his homosexuality from the affiant

at the time of marriage.

5. All the pieces of evidence appended thereto, which the

plaintiff respectfully request to be correspondingly marked as
Exhibits in this case; and
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6. All matters, facts and circumstances related to thereto, with

the reservation to present additional exhibits in the course of
the proceedings of the instant case.

PRELIMINARY STATEMENT
I, Ma. Clara de los Santos-Ibarra, of legal age, Filipino, teacher, and
with address at Unit 1501, Beacon Tower, Don Chino Roces Ave cor
Arnaiz Ave., Legazpi Village Makati, subscribing under oath, depose
and state the following answers to the questions asked by Atty. Filosofo
Tacio with Attorney’s Roll No 112358, with address at Unit 3201,
Export bank Plaza, Don Chino Roces Ave cor. Sen Gil Puyat Ave,
Makati City. The examination is being held at the same address. I am
answering his questions fully conscious that I do so under oath and
may face criminal liability for false testimony and perjury.

DIRECT TESTIMONY OF MA. CLARA DE LOS SANTOS-

IBARRA

1. Q: For the record please state your name, your age,

your address and your civil status?

A: My name is Maria Clara de los Santos-Ibarra, 30 years old,

married and currently residing at Unit 1501, Beacon Tower, Don
Chino Roces Ave cor Arnaiz Ave., Legazpi Village, Makati.

2. Q: How do you know the respondent in this case?

A: Juan Crisostomo Ibarra is my husband. We had a church

wedding on December 2, 2018 and our marriage certificate was
registered at the City of Makati.

3. Q: I am showing you a Certificate of Marriage with a

Registry No. 2018-1768. Is this your marriage certificate
your referring to?

A: Yes, Attorney.

(Manifestation: Witness answered after examining and

identifying the Certificate of Marriage.)

I would like to have the Certificate of Marriage marked

as Exhibit A. I am attaching this exhibit as part of this
Judicial Affidavit to form part of it.
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4. Q: How did you meet the respondent?

A: I met him the first time I went to Seoul in 2015 at a bus

station. Since my Korean is rudimentary at best and didn’t know
how to get around, I was relieved to see him - a kababayan (a
fellow citizen). I rushed to him and asked for directions. He
helped me get to my hotel and gave me his number in case I
needed help.

5. Q: What happened next, if any?

A: Back in the Philippines, I called him up and offered dinner

as thanks for his help. Since then we kept meeting and messaging
each other until we agreed to exclusively date after four weeks of
seeing each other.

6. Q: How long did you date?

A: We dated for two years, until he proposed to me in 2017

during our anniversary. We were fiancés for a year and then we
married in 2018.

7. Q: What was your reason for marrying the

respondent?

A: One thing I liked about him is that he respected my

boundaries. I told him that I wanted to wait after marriage before
we become intimate and he readily agreed. He never forced or
pressured me to engage in sex while we were dating. He appeared
to be content with just holding hands, hugging and the occasional
kisses.
Another thing is his lovely family. The first time I met his
family they were excited and teased that their only son is finally
getting married. Respondent’s father, who was suffering form a
throat cancer, was particularly emotional.

8. Q: How would you describe your married

relationship with the respondent?

A: We were a regular couple, however there was a little

awkwardness in the intimate department.

9. Q. What do you mean by “awkwardness in the

intimate department”?
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A: The first time we had sex, respondent was more awkward

than me. It was weird. Afterwards I felt the need to comfort him.
So, I held him, told him it’s alright and we'll get better with more
practice. In the months following our marriage, I observed that
it takes time for him to get turned on. It crossed my mind that
perhaps he's asexual. However, in hindsight I now think that
perhaps it was a red flag.

10.Q: A red flag for what exactly?

A: That he was concealing his homosexuality.

11. Q: What is the reason why you think that the

respondent is a homosexual?

A: I followed and investigated him, after an incident occurred

which made me suspect that the respondent was having an illicit
relationship. It led me to a startling revelation that he is a
homosexual.

12. Q: What incident made you suspect that the

respondent is having an illicit relationship?
A: I was diagnosed with chlamydia, a sexually transmitted
disease or “STD”, during the first year of our marriage. Since my
husband is the only sexual partner I, got suspicious that he was
having illicit relationship.

13. Q: What proof do you have that you were diagnosed

with chlamydia?

A: I have a medico-legal certificate from Ospital ng Maynila.

14. Q: I’m showing to you a Medico-Legal Certificate

from Ospital ng Maynila, dated April 2, 2019. Is this the
same medico-legal certificate you are referring to?

A: Yes, Attorney.

(Manifestation: Witness answered after examining and

identifying the Medico-Legal Certificate.)

I would like to have the Medico-Legal Certificate

marked as Exhibit B. I am attaching this exhibit as part
of this Judicial Affidavit to form part of it.
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15. Q: You stated earlier that you investigated the

respondent after the incident. How did you do it?
A: I started observing him for any unusual behavior. Such as
looking into his social media activities, who his friends are that I
didn’t know about, which pictures he liked and what occasions
he showed reactions to.

16. Q. What did you find, if any?

A: Nothing on social media.

17. Q: What did you do next, if any?

A: I secretly followed him on his gym sessions. There, I found
out that he appears to be very close with his gym buddy. He was
touchy feely with him; much more than he is with me. Afterwards
they went to a nearby amusement park. The they had dinner
together in a restaurant. It looked like they were having a date. They
left and went to what appeared to be the other guy's house.

18. Q: What happened next, if any?

A: I saw the respondent leaning in and kissing the other guy’s
neck and the hairs on the back of my neck stood up. When he
arrived late that evening I asked him where he was. He said he had
a meeting with his doctor client.

19. Q: How did you feel when you heard his response?
A: I was devastated because I knew he was lying.

20. Q: What was your mind process when you “knew” he

was lying?
A: I realized right there and then that I needed concrete proof
that he’s indeed gay before I could confront him, so I befriended the
ex-girlfriends he told me about.

21. Q: Who are these women?

A: Narcisa Cruz, Victoria Salve and Pia Wurtz.

22. Q: How did you befriended these women?

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A: I found them on Facebook and I sent them a message

politely asking about their relationship with the respondent. After
receiving the message, they were kind enough to respond.

23. Q: What is your proof of your communications with

Narcisa Cruz, Victoria Salve and Pia Wurtz?
A: I have screenshots of our conversation together with
affidavits executed by each one of them affirming their identity and
the content of the screenshots.

24. Q: I am showing to you the screen shots of the

conversations with Narcisa Cruz, Victoria Salve and Pia
Wurtz together with the corresponding affidavits. Is this
the same screenshots and affidavits you were referring
to?
A: Yes, Attorney.
(Manifestation: Witness answered after examining and identifying
the screen shots and affidavits.)
I would like to have the screenshots of communications
with Narcisa Cruz marked as Exhibit C-1 and the
corresponding JA marked as Exhibit C-1.1; the
screenshots of communications with Victoria Salve as
Exhibit C-2 and the corresponding JA marked as Exhibit
C-2.1; the screenshots of communications with Pia Wurtz
as Exhibit C-3 and the corresponding JA marked as
Exhibit C-3.1. I am attaching this exhibits as part of this
Judicial Affidavit to form part of it.

24. Q: What did you find out, if any?

A: That they were not his girlfriends. Pia Wurtz, to my utter
dejection, added that respondent had a relationship with a guy
named, Basilio so I sought him out via social media.

25. Q: What happened next, if any?

A: I sent Basilio a message and we started talking.

26. Q: What did you find out from Basilio, if any?

A: Basilio stated that he and respondent were a couple. They
were in a 5-year romantic relationship before they broke up. He
showed me remaining photos of them together and some other
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documents during their relationships such as flight details and

hotel accommodations. He told me that the reason they broke up
was that respondent’s family was pressuring him to marry
because of his father’s throat cancer and also his age.
I also found out that Basilio and respondent met a few
months before our wedding and they had intimate relations.
When I checked the date, it coincided with the date when
Crisostomo left for Bataan for what he claimed to be a supposed
seminar.

27. Q: I am showing to you Boarding Passes and a Hotel

Receipt. Are these the same flight details and hotel
accommodations provided by Basilio de Dios that you
were referring to?
A: Yes, Attorney.
(Manifestation: Witness answered after examining and identifying
the Boarding Passes and the Hotel Receipts.)
I would like to have the Boarding Passes marked as
Exhibit D and the Hotel Receipt marked as Exhibit E. I am
attaching this exhibits as part of this Judicial Affidavit to
form part of it

28. Q: How did you feel when you learned about the
respondents previous romantic relationship with
Basilio?
A: I was shaken because prior to marriage I did not have any
reason to believe that respondent was a homosexual. He did not
tell me anything about it. He concealed it by making me believe
that he had previous girlfriends. He even wrote it in a Valentine
Card he gave me.

29. Q: I am showing to you a Valentine Card dated

February 14, 2017. Is this the same valentine card that
you were referring to?
A: Yes, Attorney.
(Manifestation: Witness answered after examining and identifying
the Valentine Card.)
I would like to have the Valentine Card marked as Exhibit
G. I am attaching this exhibit as part of this Judicial
Affidavit to form part of it
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30. Q: What happened after your conversation with

Basilio, if any?
A: In October 21, 2019, I confronted respondent if he is a
homosexual. He vehemently denied it. However, when his
relationship with Basilio was brought up, for a moment he looked
very shocked then he got very mad at the me. It was the first time
I ever saw him red, about to burst with rage and spewing hurtful
words towards me. His reaction was so out of character that I could
not recognize him as the same person I had married.

31. Q: What happened after the confrontation, if any?

A: We were never the same again. The very next day after the
confrontation, I left the house to stay with my sister.

32. Q: What was your reason for leaving the house?

A: He made me believe he was a heterosexual man before
marriage, and I only found out later on that he is gay after I did
my own investigation after he infected me with an STD. I did not
and I still do not want to stay with him as his wife, because I
would not have married him if I knew he is a homosexual.

33. Q: Do you attest to the truthfulness and veracity of the

contents of your judicial affidavit?

A: Yes, Attorney.

No more further questions.

IN WITNESS WHEREOF, I have hereunto set my hand this

12thday of March 2021.

MA. CLARA DE LOS SANTOS-IBARRA

Affiant
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SWORN ATTESTATION

The undersigned hereby attests that, as counsel of the witness she

has faithfully recorded the questions he asked and the
corresponding answer of the witness and that he did not coach the
witnesses’ answers to the questions propounded.

TACIO AND ASSOCIATES LAW OFFICES

37th Floor, Rufino Pacific Tower
6784 Ayala Ave. cor. V.A. Rufino St.
Makati City

By:

ATTY. FILOSOFO TACIO

Roll No. 64635
PTR No. 2438456D |10-01-2020 | Makati City
IBP No. 109345 | 09-01-2020 | Makati City
MCLE Compliance No. VI-0025845 | 16-04-19

***** JURAT *******

SUBSCRIBED AND SWORN to before me this 12th day of March,

2021, at Makati City; affiant exhibiting to me his Passport No.
EC1234 as competent evidence of his identity.

Doc. No.____87__;
Page. No.___34___;
Book No. ____03___;
Series 2021