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PRE-TRIAL SCRIPT

CHARACTERS:

Judge – Eisley

Counsel for Petitioner- Wilven

Counsel for Respondent - Mark

Clerk of Court -

Clerk of Court: All rise! Honorable Judge Eisley Garcia is in court. Let’s pray.

Almighty God, we stand in Your Holy Presence as our Supreme Judge.


We humbly beseech You to bless and inspire us so that what we think, say and do will
be in accordance with Your will. Enlighten our minds, strengthen our spirit and fill our
hearts with fraternal love, wisdom and understanding, so that we can become effective
channels of truth, justice and peace. In our proceedings today, guide us in the path of
righteousness for the fulfillment of Your greater glory. Amen.

(Tatayo lahat)

Judge: Court is now in session. Call the cases.

(Upo lahat)

PRE-TRIAL

Clerk of Court: For arraignment: Criminal Case No. 4444-000 People of the
Philippines v. Juan P. Kidnapero for the crime of kidnapping.

Clerk of Court: Appearances for prosecution and the defense.

PROSECUTION: Your honor, I am Atty. Wilven Sinlao appearing as counsel for the
petitioner. Ready your honor.

DEFENSE: Your honor, I am Atty. Mark Lester Basa appearing as counsel for the
respondent. Ready your honor.

JUDGE: Now, will the distinguished counsel of the respondent admit the following
facts as appearing in the pre-trial brief of the petitioner:

Q: Does the respondent admit to be the same MARKO A. LIQUIRAN that is


the person married to the petitioner WILMA SINLAO-LIQUIRAN?

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PRE-TRIAL SCRIPT

DEFENSE: Yes, your Honor.

Q: Does the respondent admit that he is the father of the two children
born by the petitioner WILMA SINLAO-LIQUIRAN?

DEFENSE: Yes, your Honor.

Q: Does the respondent admit the de-facto separation between him and the
petitioner?

DEFENSE: Yes, your Honor.

Q: Does the respondent admit that he entered into an extramarital relationship


with another woman named JOLENE MORENO?

DEFENSE: No, your Honor.

Q: Does the respondent admit that he is the father of the two children born by
JOLENE MORENO?

DEFENSE: No, your Honor.

Q; Does the respondent admit that he made a Letter of Agreement together


with the petitioner, him promising monthly financial support for their children?

DEFENSE: Yes, your Honor.

Q; Does the respondent admit that he failed to give monthly financial support
for his and the petitioner’s children?

DEFENSE: No, your Honor.

Q; Does the accused admit the jurisdiction of this court?

DEFENSE: Yes, your Honor.

JUDGE: Please take note of this stipulations, Clerk of Court. Does the prosecution
have any comments?

PROSECUTION: No, your Honor.

JUDGE: Now we proceed to the evidences to be presented by both parties.


Prosecution counsel may start.

PROSECUTION: I have here with me your Honor documentary evidences which I


move to be marked as Exhibit A to Exhibit E.

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PRE-TRIAL SCRIPT
Your honor, Exhibit A is the Certificate of Marriage to prove the fact of marriage,
parties having been married on June 20, 2011.

JUDGE: Mark it.

PROSECUTION: Exhibit B-1 and B-2, your Honor is the Birth Certificate of petitioner
and respondent’s two children to prove that the parties share two children.

JUDGE: Mark it.

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PRE-TRIAL SCRIPT

PROSECUTION: I will now proceed with Exhibit C-1 and C-2, your Honor which is the
Birth Certificate of respondent’s two children born out of wedlock to prove that the
respondent have entered into an extramarital relationship with Jolene Moreno.

JUDGE: Have it marked.

PROSECUTION: For Exhibit D, your Honor, is the Affidavit of Acknowledgment of


Paternity signed by the respondent to prove that the respondent is completely
acknowledging the two children of Jolene Moreno as his and that the same children
were born out of wedlock.

JUDGE: Have it marked.

PROSECUTION: Exhibit E, your Honor is the Letter of Agreement between the


petitioner and respondent for the latter’s monthly financial support for their two
children to prove that the respondent failed to comply with the essential marital
obligations of marriage. Such deliberate refusal to give support paired with the
respondent’s refusal to live with the petitioner who is without fault is a manifestation
of psychological incapacity on the part of the respondent.

JUDGE: Mark it. Are there any additional exhibits to be presented prosecution counsel?

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PRE-TRIAL SCRIPT
PROSECUTION: None, your Honor.

JUDGE: Counsel for the defense, please proceed with your evidences to be
presented.

DEFENSE: Thank you, your Honor. I have with me the Drug Test result of the
petitioner as Exhibit A to prove that it is the petitioner who neglects her duties to
the conjugal union and committed acts, like drug addiction, which brought danger,
dishonor or injury to their family.

JUDGE: Mark it.

DEFENSE: Exhibit B your Honor is the Incident report form prepared by Brgy.
Secretary Marites Dizon due to the petitioner’s frequent intoxication which led to a
grave disagreement between the parties. This proves that it is the petitioner who
failed to comply with the essential marital obligations of marriage. Your Honor, we all
know that frequent intoxication is a ground for declaration of nullity of marriage
which shall be considered as psychological incapacity on the part of the petitioner.

JUDGE: Have it marked. Are there any additional exhibits to be presented


defense counsel?

DEFENSE: That would be all your Honor. Thank you.

JUDGE: Any further comments counsels?

DEFENSE & PROSECUTION: None your Honor.

JUDGE: There being no other evidence to mark, set the case for pre-trial on April
5, 2018 at 4 pm. Session adjourned.

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PRE-TRIAL SCRIPT

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