Undisputed facts (alleged by other party; admitted by our party):

1. They met in October 1992

a. Started sexual relationship
2. Cohabited since 1996
a. UPDATE: THEY CHANGED THIS IN ERICS JA AND SAID THAT
COHABITATION STARTED IN 1993.
b. UPDATE: HE SAID COHABITATION HAS ALWAYS BEEN IN MAKATI
CONDOMINIUM
3. First baby (Roxanne) in 2000
a. Moved to Makati condominium
4. Married in 2005 (civil rights); church wedding (2006)
5. Eric legally adopted Maxim on the same year of wedding (2006)
6. 2 more kids followed: Joy (2007) and Jaya (2009)
7. They moved to Quezon City house in 2010.

NOTES ON ERICS JA:

1. Complaint states cohabitation only lasted for 4 years since Kimmy got pregnant with
Roxanne. JA stated cohabited in 1993.
2. They are trying to show that Kimmy was already previously admitted in Droga
Foundation in 1991 and then admitted again in 2011.
3. He said that they stayed in Makati Condominium even after marriage.
4. He said in his JA that he left their Makati Condominium. BUT complaint shows that
he left their QC home.
5. Bank book only shows 2011 and 2012. No withdrawals.
a. Our attachment shows a more recent withdrawal from bank book and
inconsistent deposits recently
6. Possible arguments on their attachments
a. He has been estranged with his wife since 2011. He hasnt seen her or his
children. Everything he knows about her is mere hearsay.
b. Grocery receipts, utility bills, tuition fees, hospital receipts will show that
expenses every month exceed 200,000.
7. The JA is inconsistent with the facts stated in the Dr. Cenzons report which states
that Eric had custody of the children
8. States that Maria is the one taking care of the children although Marias affidavit
states that she merely assisted Kimmy
9. Note: An affidavit of desistance from the victim does not preclude the state from
prosecuting a crime against persons. The dismissal of the case must have been for
other reasons like lack of cause of action or nuisance.
10. Note: If Erics primary concern is the childrens welfare, he should have already filed
for custody pending the proceedings or even before its institution. That, he failed to
do/

Strongest points against Eric:

- He had reasonable amount of time to learn about Kimmy and to discover Kimmys
vices and psychological problems (8 years since theyve met, 4 years of cohabiting
before Kimmy got pregnant with Roxanne).
 - When he left their family home (Quezon City) in 2011, he left the kids with her. If he
truly believes that Kimmy is violent and dangerous, he wouldnt have left them with
her.

PURPOSE:
1. Establish that Eric had reasonable amount of time to learn about Kimmy and to
discover Kimmys vices and psychological problems (8 years since theyve
met, 4 years of cohabiting before Kimmy got pregnant with Roxanne).
2. Prove that theyve been having sex since 1992. It was not a one night stand. It
has been a long sexual relationship which only resulted to Kimmys pregnancy
in 2000.

1. When/Where/How did you meet?

2. Where were you living at the time you met?
3. Was it true that you had been frequently going out with Kimmy and your other friends
after you met her?
4. In 1996, was it true that you were ejected out of your previous condominium and you
gladly accepted an offer from kimmy to stay in a spare room in her apartment?
5. How long have you been living together before Kimmy got pregnant with Roxanne?
6. Did you have any intimate relationship with Kimmy during the time that you were
living together?
7. You mean that in the 7 years of being together prior to her pregnancy with Roxanne,
not once have you observed her drinking up to the moment she passed out? Or
thats shes a drug user?
8. In the very long time that youve been together since 1993, 7 years prior to
Roxannes birth, you did not leave her even if she was allegedly unstable?

PURPOSE: Establish that the underlying motive for Eric to file the Petition for
declaration of nullity of marriage with Kimmy is the fact that he is no longer satisfied
with his marriage with Kimmy.

1. Describe your relationship with Kimmy.

2. Were you happy with your sex life?
3. Were you attempted to look for someone else to satisfy your sexual appetite?
4. In those cases that you and Kimmy were fighting, what did you do?
5. Then where do you go?

PURPOSE: Establish that Eric was lying when he said that Kimmy was violent and
dangerous by pointing out that if Kimmy were really violent and dangerous, Eric
would not have left the children alone with Kimmy.

1. How can you describe Kimmys relationship with her son?

2. Your relationship with her son?
3. You stated in your Judicial Affidavit that Kimmy has a tendency to be wild and
uncontrollable. If its true that you think Kimmy was violent and dangerous to you
and your kids, then why did you leave them to her care?
PURPOSE: Establish that Eric was lying when he said that Kimmy was violent,
dangerous and that she returned to her vices after admitting herself to Droga
Foundation

1. You said that you learned from Kimmy that she used to work in a bar as a promo girl,
how did you know that when you admitted that she is very secretive and shuts down
herself from you and your kids.
2. If you already left before she admitted herself to the Droga Foundation, then how did
you know that she returned to her vices?

PURPOSE/S:
1. Establish that Erics monthly support to Kimmy is not sufficient to sustain the
needs and expenses of the 4 children.
2. Prove that Kimmy had to pawn the jewelries not by reason of her drug
addiction nor alcohol abuse but only to support the other expenses of the 4
children

1. How sure were you that she pawned the jewelries by reason of her drug addiction
and alcohol abuse, and not to support the 4 kids you left with her
2. Do you know that the total amount of tuition fee of your children is ______?
3. Would you have an idea as to the amount of monthly expenses of your 4 children?
4. How much is your monthly support to Kimmy and the 4 children?
5. Do you think the monthly support that you are giving to your children is sufficient to
meet their needs and expenses?

PURPOSE/S:
1. Establish that Eric and Dr. Cenzon are together, thus the report of Dr. Cenzon
is unreliable and biased.
2. Establish that the means by which Dr. Cenzon assessed the psychological
incapacity of Kimmy was unreliable

1. How long have you known Dr. Cenzon?

2. Is it true that you and Dr. Cenzon were together during [INSERT DATE]? How long
have you been together?
3. I will show you pictures of you and Dr. Cenzon, with your arms around Dr. Cenzon in
three different dates, 2010-2011.
4. At the time that you got married with Kimmy, were you still communicating with Dr.
Cenzon?
5. Why did you choose Dr. Cenzon to conduct an examination and assessment of the
psychological incapacity of your wife Kimmy?
6. How did you get the help of Dr. Cenzon in assessing your and Kimmys the
psychological fitness?
7. How did Dr. Cenzon examine your psychological fitness?
8. How did Dr. Cenzon examine Kimmys psychological fitness?

DR. CENZON
1. How did you?
2. Bakit same ng address

MARIA CUENCA

1. Real mother Kimmy as irreplaceable

2. Kahit sinisigawan mga bata
3. Di lang si nanay Maria yung

OBJECTIONS:
1. Ambiguous and Unintelligible
2. Asked and Answered
3. Argumentative
4. Assuming Facts Not in Evidence
5. Privileged Communication
6. Compound
7. Hearsay
8. Immaterial
9. Irrelevant
10. Leading
11. MIsquoting a Witness
12. Calls for a Narrative
13. Non-Responsive
14. Calls for an Opinion
15. Parol Evidence
16. Self-Serving
17. Calls for a Speculation

OBJECTIONS ON JA:
1. General
a. Wrong margins

2. Eric
a. [INSERT] hearsay testimony for Ms. Alejo and Dr. Cenzons report
3. Maria (the housekeeper)
a. Q23 hearsay
4. Jen Santos (Droga Foundation supervisor)
a. Q7 irrelevant whos Kimmy I. Dora?
b. Q12 hearsay but they can say na the purpose is just to say na Kimmy
did the admitting, not the truth of such assertion
5. School Administrator (HS dropout)
a. No signature
6. Bianca Mendez
a. No name of attorney
 7. Dr. Cenzon
a. Q7 not annulment
b. Q15 leading question
c. Q22 leading
8. Ms. Alejo
a. No signatures of notary publics
9. Marvin Magdangal (Blotter Report)
a. Q9 opinion rule
10. Jose Ignatuis (BMW Car)
a. A11 incomplete
b. A12 hearsay
c. A 15 hearsay
d. no signatures
11. Mark Garcia (Forged Deed of Sale)
a. A16 hearsay
b. A23 hearsay
c. A 25 hearsay
d. A 26 hearsay
e. A 28 hearsay
12. Martin De Castro (Lannister Pawnshop)
13. Pawnshop Manager
a. no signatures

RE-CROSS
1. Recommend immediate dissolution of marriage
2. Not possible for reconciliation
3.