Republic of the Philippines

Third Judicial Region

REGIONAL TRIAL COURT
Muntinlupa City
Branch ___

People of the Philippines,

                  Plaintiff,

              CRIMINAL CASE NO. 000-M-

20__
-versus- FOR: SERIOUS PHYSICAL
INJURIES

Jose Santos,
                         Defendant.
x - - - - - - - - - - - - - - - - - - - - - - - - - - - - -x

JUDICIAL AFFIDAVIT
OF IVY PATDU

I, DR. Ivy Patdu, of legal age, Filipino, married, Physician and a resident of
Alabang Hills Village, City of Muntinlupa, after having been sworn in accordance
with law, by way of this Judicial Affidavit, hereby testifies before this Honorable
Court as follows:

The person examining me is Atty. Rachel Jane B. Regaspi, with office

address at Unit 902, Prime Land Ventures Bldg., Market Street, Madrigal Business
Park, Ayala Alabang, Muntinlupa City. The examination is being held at the same
address. I am answering her questions fully conscious that I do so under oath and
may face criminal liability for false testimony and perjury.

That the purpose of the instant testimony is being offered to prove among
other, that the witness is an expert witness; the fact that the witness herein is the
physician of the plaintiff; and the plaintiff in this case suffered serious physical
injuries as a result of being hit by a jeepney driven by the defendant;

1. Q: Please state your name and other personal circumstances for the record.

A: I am Ivy Patdu, 40 years old, married, residing in Alabang Hills Village,

City of Muntinlupa;

2. Q: Doctor, you stated that you are a Physician, will you state some of your
qualification, if any?
 A: I am a graduate of Doctor of Medicine at University of the Philippines-
Manila in 2002, after passing the Licensure examination, I specialize in Data
Privacy and Health Law. I am a consultant for privacy and other legal issues
for both government and private sector, including the UP National
Telehealth Center, I am also a graduate of Master in Hospital Administration
at University of the Philippines- Manila in 2018;

3. Q: Doctor, what is your current employment?

A: I am a medico-legal officer at Ospital ng Muntinlupa. I am also teaching

Legal Medicine at the Ateneo de Manila Law School and San Beda College
Alabang Law School;

4. Q: Doctor, you mention that you are a medico-legal officer, can you
elaborate more on what you do as a medico-legal officer?

A: As medico-legal officer,
4. Q: Doctor, do you know Kimberly R. Resurreccion-Santos?
A: Yes, she is my regular patient.

5. Q: How about the defendant of this case, Jay Mark A. Santos, do you know
him?
A:Yes. He is the lawful husband of my patient, Kimberly R. Resurreccion-
Santos

6. Q: Do you have any idea what the case is about?

A: Yes. It is a civil case for annulment of marriage filed by my client against
her husband.

7. Q: How and when did you first met the plaintiff of this case?
A: She went to my clinic at 05 Cadena De Amor St. Alido Heights, Malolos
City, Bulacan on October 12, 20___.

8. Q: And what happened next?

A: She asked for a regular check-up about her health. Wherein I conducted
the necessary tests to know her condition.

9. Q: And what did you find out?

A: She is healthy and is at the optimum time to be pregnant and have a child
birth.

10.Q: And what happened next?

A: She continued her regular visits from then on, until she requested my
assistance to conduct an examination for her.

11.Q: Can you tell the court what kind of examination was it?
 A: Yes, she requested if I could examine her and verify if she was still a
virgin.

12.Q: Did she tell you the reason why she wanted to know?
A: Yes, she claimed that she will use the result of the examination with
regard to the nullity of her marriage with the respondent.

13. Q: And after Kimberly Resurreccion presented herself to you for an

examination with respect to her intention to nullify her marriage, what
happened next?
A: Initially, I first did some probing questions to her in order to determine if
there are valid reasons for the filing of nullity of marriage by the said client.

14. Q: And what is the result of those probing questions that you said you have
conducted on Mrs. Santos?
A: After doing it, I found out that there are indeed valid reasons.

15.Q: When was the examination done, if you still recalled?

A: It was only a month after she filed a case for annulment against her
husband.

16.Q: Can you tell the court the exact date of such examination?
A: Yes. It was on _______________

17.Q: You said you examined her, where did you examine her?
A: At my clinic in Alido Heights.

18.Q: Ms. Witness, can you elaborate when you said that she is requesting you
to verify her virginity, what examination is the plaintiff requesting?
A: The plaintiff is requesting that her hymen be checked if it was still intact.

19. Q: Ms. Witness I am showing you a document of a medical report (Exhibit

“___”). Do you recognize it?
A: Yes, Sir.

20.Q: Can you tell us what is this document about?

A: Yes, Sir. This is the medical report I personally written to document my
findings on the status of the hymen of the Plaintiff.

21.Q: What does the medical report says?

A: The report shows that the plaintiff has her hymen still intact despite being
married for three years now.

22.Q: Can you elaborate, for the purpose of this testimony, the meaning of “her
hymen still intact?”
A: In medical impression, it means that the hymen has not been penetrated
or abused by any object.

23. Q: Is there anything else you wanted to testify?

 A: Nothing further.

Malolos City, Bulacan _______ ___, 2019.

(THIS PORTION WILL BE EDITED AFTER GROUP APPROVAL)

Affiant

            SUBSCRIBED and sworn to before me in Malolos City, Bulacan on

__________ ____, 20___, affiant showing his/her competent proof of identity, to
wit: ID: _____________________________

                                                                                                Notary Public

Doc. No. __
Page No. __
Book No. __
Series of 20__.

IV.              EXHIBITS ATTACHED TO THE JUDICIAL AFFIDAVIT.

Exhibit “____”

V.                SWORN ATTESTATION OF THE LAWYER WHO

CONDUCTED OR SUPERVISED THE EXAMINATION OF THE
WITNESS.

The undersigned ATTY. _____________________, of legal age, married, and

with law office address
__________________________________________________________________
_____ under oath, deposes and states:

1.       He is the Legal Counsel for the plaintiffs in the above-entitled case;

2.      He  faithfully  recorded  or  caused  to  be  recorded  the questions  he  asked 
and  the corresponding  answers  that  the above-named witness gave;

3.      Neither he nor any other person then present or assisting him coached the
witness regarding the latter's answers; and

4.      He conducted the examination of the witness at his law office located at
_____________________
________________________________________________________________.
Malolos City, Bulacan ________ ____, 2019.

_Atty.___________________________
Affiant

            SUBSCRIBED and sworn to before me in Malolos City, Bulacan on

______________ _____, 20___, affiant showing his/her competent proof of
identity, to wit: ID: _________________________________.

                                                                        Notary Public

Doc. No. ___

Page No. ___
Book No. ___
Series of 2015.
Copy Furnished:

Xxx LAW OFFICES

Counsel for Defendant XXX
xxx Floors
xxx CENTER
xxx Ave. corner xxx St.
xxx, xxx City
xxx City
                                    Reg. Rec. No.
                                    Date                                                    PO
           
Register of Deeds  of Rizal Province
Office of the Register of Deeds
Of Rizal Province
Binangonan, Rizal
                                    Reg. Rec. No.
                                    Date                                                    PO

EXPLANATION

            A copy of this Judicial Affidavit is served on the Court, the Counsel for the
Defendant and the Register of Deeds of Rizal Province via LBC Express
Corp./registered mail due to the great distances of their respective addresses, due to
the urgency of filing the same, and due to the lack of field personnel of the
undersigned counsel at this time.

                                                                                    NAME