Republic of the Philippines

REGIONAL TRIAL COURT

First Judicial Region
Branch 1
San Carlos
Pangasinan

WILMA SINLAO-LIQUIRAN
Petitioner,

- versus - CIVIL CASE NO. 2022-01-05

For: Declaration of Nullity of Marriage

MARKO A. LIQUIRAN,
Respondent,
x----------------------x

PRE-TRIAL BRIEF

PETITIONER, by the undersigned counsel and unto this Honorable Court

most respectfully states:

STATEMENT OF THE FACTS AND OF THE CASE

This is an action for Declaration of Nullity of Marriage under Articles 36, 68

and 72 of the New Family Code.

Petitioner alleges in his Petition, viz: a) that petitioner and respondent are
husband and wife; b) that the respondent’s non-performance of essential marital
obligations stated under the Family Code constitutes psychological incapacity; c) that
such psychological incapacity is a ground for declaration of nullity of marriage;

Petitioner likewise alleges that two children were born in wedlock and their de-
facto separation which culminated from petitioner’s frustration of respondent’s
mercurial change of disposition, manipulative conduct, immaturity and extramarital
conduct. That respondent failed to give love, emotional support and fidelity to the
marriage. That respondent entered into an extramarital relationship with another
woman named Jolene which resulted to two children born out of wedlock.

PROPOSED STIPULATION OF FACTS

1. The identity of parties as petitioner and respondent;

2. The fact of marriage, parties having been married on June 20, 2011;
3. The two children were born in wedlock;
4. Their de-facto separation and the absence of cohabitation between
the spouses.
5. The respondent entered into an extramarital relationship with another woman.
6. The two children of the respondent from the other woman were born out of
wedlock.

LIST OF DOCUMENTARY EVIDENCE

1. Marriage Contract ----Exhibit "A"

2. Birth Certificate of petitioner and respondent’s two children-----Exhibit "B-1" and
“B-2”
3. Birth Certificate of respondent’s two children born out of wedlock----Exhibit "C-1"
and “C-2”
4. Affidavit of Acknowledgment of Paternity-----Exhibit “D”

ABSTRACT OF TESTIMONIES

Petitioner will be testifying on the allegations in the Petition and will present
documentary evidence.
 NUMBER OF WITNESSES TO BE PRESENTED

Petitioner and at least two (2) witnesses.

ADMISSIONS

Outside of the matters alleged, petitioner is not inclined to admit further

matters.

APPLICABLE LAWS AND JURISPRUDENCE

Provisions on the Family Code.

ISSUES

Whether or not respondent is psychologically incapacitated to comply with the

essential requisites of marriage which is a valid ground under Art. 36 of the New
Family Code to declare the marriage a nullity.

AVAILABILITY FOR TRIAL

Counsel will be available for trial on dates convenient with this

Honorable Court.

Respectfully Submitted:

Quezon City. January 5, 2022.

Garcia, Sinlao and Associates Law Offices

Counsel for Petitioner
145 Tandang Sora,
San Carlos City, Pangasinan
IBP No. 764814 dtd. 01-07-21 San Carlos City
PTR No. 5448574 /01/14/09/ San Carlos City
MCLE Compliance II – 0009328
Dtd. March 27, 2021

Copy furnished:
Office of the City Prosecutor ------------------- Personal Service
San Carlos City

Office of the Solicitor General ----------Registered Mail w/ Return Card

123 Quezon Boulevard
San Carlos City, Pangasinan
A
B-1
B-2
C-1
C-2
D