Republic of the Philippines

Regional Trial Court

National Capital Judicial Region
Muntinlupa City
Branch 143

PEOPLE OF THE PHILIPPINES,

-versus- Criminal Case No.: 0014344

For: Homicide

GERALD SAMDERSON,
Accused.

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JUDICIAL AFFIDAVIT
OF EXPERT WITNESS

I, Kimmy Chiu, 35 years old, married, residing at 143 Mabuhay St.,

Sampaloc, Manila, employed as a Psychiatrist at the National Center for
Mental Health after having been duly sworn to in accordance with law, hereby
depose and state:
PRELIMINARY STATEMENT

That in accordance with A.M. No. 12-8-8-SC, which prescribes the

use of judicial affidavits to serve as the direct examination testimony of the
witness, on the basis of which the adverse party may conduct their cross-
examination on such a witness, I hereby execute this judicial affidavit in a
question and answer format;

That conformably with section 3 (b) of the said A.M. No. 12-8-8-
SC, I also state that it was Atty. Mikhail Trinidad, counsel for the accused
Gerald Samderson, who conducted the examination in his office at 123
Espana Blvd., Sampaloc, Manila

That conformably also with section 3 (c) thereof, I hereby state

under the pain of perjury that in answering the questions asked of me, as
appearing herein below, I am fully conscious that I did so under oath, and that
I may face criminal liabilities for false testimony or perjury;

The affidavit and testimony of the witness is offered to prove:

1. That the accused was a patient of the National Center for Mental Health
at the time the alleged killing transpired
2. That the accused was diagnosed with Chronic Schizophrenia.
3. That the accused, being a schizophrenic, was completely deprived of
intelligence when he committed the act.

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Q1: Ms. Witness, can you please state your full name and personal
circumstances?
A1: Yes, sir. I am Kimmy Chiu and I am currently connected as a
licensed Psychiatrist for the National Center for Mental Health.

Q2: How long have you been a licensed psychiatrist?

A2: For 15 years now.
Q3: How long have you been connected with the National Center for
Mental Health?
A3: for 10 years now.

Q4: Do you know the accused Gerald Samderson?

A4: Yes, sir.

Q5: How did you know him?

Q5: He was my patient at the National Center for Mentalh Health?

Q6: How long has he been your patient?

Q6: About 5 years now, sir. He was first brought to me as an outpatient
in August of 2018.

Q7: Did you conduct some series of evaluation or assessments on the

accused?
Q7: Yes, sir.

Q8: What were these assessments?

Q8: As part of our Standard Operating Procedure, we had to conduct
first physical checks on the patient which included CT Scan and MRI
on the brain. After which, I conducted the Positive and Negative
Syndrome Scale.

Q9: What is this Positive and Negative Syndrome Scale?

Q9: It is an interview conducted on the patient and a member of his
family or caregiver checking on the behavior of the patient. I checked
for any medical history and behavioral symptoms.

Q10: Was this the only evaluation or assessment conducted on the

accused?
Q10: No, sir.

Q11: What were the other tests?

Q11: I also conducted the Brief Psychiatric Rating Scale or BPRS

Q12: And what does this test entail?

Q12: This test looks at 18 symptoms of behavior such as, but not limited
to, hostility, disorientation, and hallucination and ranks each on a scale
of 1, for not present, and 7, for extremely severe.

Q13: Were there other tests?

Q13: None, sir.

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Q14: How would you describe the accused physically when he was first
brought to you?
Q14: The patient was very thin and in a malnourish-like state.

Q15: How would you describe the mental state of the accused when he
was first brought to you?
Q15: The patient was very timid. He didn’t have eye contact when I
was assessing him. His eyes would roam around the place but never
towards me. In some occasions, he would murmur to himself
unintelligible words.

Q16: Why was the accused brought to you?

Q16: According to his mother, prior to the patient visiting our clinic, he
was displaying changes in behavior. He barely ate and unable to sleep.
There was even appoint, according to his mother, that the patient talked
for 12-hours non-stop.

Q17: After conducting all the series of tests to the accused, what were
your findings?
Q17: The results came out that the patient was suffering from Chronic
Schizophrenia

Q18: In a language that a lay person could understand, can you please
tell us what Chronic Schizophrenia is?
A18: Yes, sir. Schizophrenia is a severe mental disorder which is
characterized by a wide range of unusual behaviors: hearing voices
(hallucinations) and distorted or false perception, often bizarre beliefs.
They are unable to distinguish between reality and imaginative events.

Q19: What were the symptoms that were manifest on the accused?
Q19: First, he was hallucinating. He told me that he was seeing black
figures that no other normal could see. Second, he was delusional, he
had the impression that someone was following him around when, in
reality, he has not gone out and never left their abode. Third, he had
disorganized thinking, at one point during our assessment, the patient
was mumbling to himself, and when I asked him about it he said
nothing but nevertheless continued talking to himself.

Q20: Do people from schizophrenia get cured?

Q20: No. There is no known cure for schizophrenia as well. However,
interventions and medications can help in improving a patient’s life and
live independently.

Q21: Was the accused admitted?

Q21: Yes, sir. We deemed it necessary to admit the patient so we can
administer medications to him, and have him undergo cognitive
behavioral therapy.

Q22: What medications were prescribed to the patient?

Q22: Antipsychotic drugs sir such as Risperidone, Quetiapine, and
Melatonin

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Q23: What are these medications for?
Q23: Risperidone is administered to help the mood of the patient.
Quetiapine is administered to reduce hyperactivity in the brain, and
Melatonin to help the patient sleep at night.

Q24: How long was the patient confined at the National Center for
Mental Health?
Q24: About a year, sir.

Q25: When was he released?

Q25: He was released in October 2019

Q26: He was released because he got cured?

Q26: No, sir. He was released because there was a significant
improvement in his psychosocial and motor skills.

Q27: What were these improvements?

Q27: He was able to bathe and eat on his own. The patient also started
to become more responsive and, at times, was able to engage in
conversations.
Q28: Was the patient removed from his medications after being
discharged?
Q28: No, sir. He still had the same medications although we reduced
the dosages.

Q29: Apart from medications, was the patient subjected to other

treatments after being discharged?
Q29: Yes, sir. We had monthly check-ups. Apart from that, he still had
to continue with his CBT with one of our psychologists.

Q30: Did the patient have other series of attacks after being discharged?
Q30: Yes, sir.

Q31: How many times did these attacks occur and when?
Q31: 3 times. First was in March of 2020. Second was in December of
2020, and the last one was in June of 2022.

Q32: Was the patient re-admitted?

Q32: Not during the first two instance, sir.

Q33: Why?
Q33: The first two attacks happened during the middle of the pandemic,
and consultations were done online instead. For the last attack, that was
when the patient was readmitted.

Q34: What was the state of the accused when he was readmitted back
in June, 2022?
A34: Like the first time he was brought in, he was hallucinating,
delusional, and had disorganized thoughts.

Q35: Did his condition ever improve?

Q35: No, sir.

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 Q36: Would you say that patients who are diagnosed with Chronic
Schizophrenia are completely devoid of their mental faculties?
Q36: Yes, sir. The mental state and symptoms of patients who are with
Chronic Schizophrenia deprive them of the full cognizance of their
mental faculties and actions.

Q37: Even at the time when he escaped the mental facility?

Q37: Yes, sir.

Q38: I have no further questions. Do you have anything to add or

retract, Dr. Chiu?
Q38: None, sir.

Q39: Were you threatened, or under the state of compulsion during this
session?
Q39: No, sir. It was voluntarily made and with my own free will.

----END OF STATEMENT----

IN WITNESS WHEREOF, I hereunto set my hand below this 22nd day of August
2023 at Trinidad Law Office, 123 Espana St., Sampaloc, Manila.

________________________
Affiant

I certify that I personally examined the herein affiant and that she voluntarily
executed and fully understood her statements.

Mikhail Matrix B. Trinidad

Administering Officer

SUBSCRIBED and sworn to before me, in the City of Manila, this 22 day of
August, 2023 by Kimmy Chiu, who exhibited to me her VALID ID with No.
C06-19-001234 issued at LTO – Manila valid until DECEMBER 21, 2025.

Notary Public
Doc. No. ______;
Page No. ______;
Book No. ______;
Series of 2023;