REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

NATIONAL CAPITAL JUDICIAL REGION
Branch 28
QUEZON CITY

IN RE: PETITION FOR

GUARDIANSHIP OF ANNE
VICERAL SMITH
JOSE MARIE “VICE GANDA”
BORJA VICERAL
Petitioner

Sp. Proc. No. 08-2078

In Re: Petition for Guardianship

ANNE VICERAL SMITH,

Oppositor,

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FORMAL OFFER OF DOCUMENTARY EVIDENCE

PLAINTIFF by the undersigned counsel and unto this Honorable Court, most
respectfully offers in evidence the following documentary exhibits for the above titled case, to
wit:

EXHIBIT DESCRIPTION PURPOSE/S

“A” Birth Certificate of Petitioner To prove the identity of the
Jose Marie “Vice Ganda” petitioner.
Borja Viceral
“B” Birth Certificate of the ward To prove the identity of the
Anne Viceral Smith ward.

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“C” Medical Certificate To prove that the ward is
authenticated by Dra. Maria incompetent person due to
Rivera her suffering from severe
bipolar syndrome.

“D” Divorce decree obtained by To prove that the father of the

the father of the ward in ward is not qualified to take
California, United States of care the properties and the
America person of the ward.
“E” Marriage Certificate of To prove that the father of the
Charles with another woman ward is not qualified to take
“F” and wedding photos. care the properties and the
person of the ward.
“G” Death Certificate of Karyl To prove that the mother of
Viceral Smith, ward’s the ward is not qualified since
mother. she already died in a
vehicular accident.

“H” Employment Contract of Jose To prove that Jose Marie

Marie “Vice Ganda” Viceral “Vice Ganda” Viceral is
qualified to be granted the
letters of guardianship of the
ward over her person ad
property of the ward.
“I” Franchise Contract and To prove that Jose Marie
Businesses of Jose Marie “Vice Ganda” Viceral is
“Vice Ganda” qualified to be granted the
letters of guardianship of the
ward over her person ad
property of the ward.
“J” College Diploma of Dra. To prove that the witness is a
Maria Rivera medical doctor, who
specializes in mental health,
including substance use
disorders and as such, has
considerable expertise and
extensive experience in
conducting examinations and
tests for the purpose of
identifying mental disorders.

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 “K” Post Graduate Diploma of To prove that the witness is a
Medicine of Dra. Maria medical doctor, who
Rivera specializes in mental health,
including substance use
disorders and as such, has
considerable expertise and
extensive experience in
conducting examinations and
tests for the purpose of
identifying mental disorders.

“L” Psychological Report To prove that the witness

evaluated and issued by Dra. conducted and assessed both
Maria Rivera – Date of the mental and physical
Report: 2012 aspects of psychological
problems of the ward.

“M” Photos of Anne’s slashed To prove that the ward is

wrist incompetent person due to
having suicidal incidents.
“N” Medical Record in Philippine To prove that the witness
General Hospital – Manila conducted and assessed both
the mental and physical
aspects of psychological
problems of the ward.
“O” Psychological Report To prove that the witness
Assessment issued by Dra. conducted and assessed both
Maria Rivera – Date of the mental and physical
Report: 2018 aspects of psychological
problems of the ward.

With the above-enumerated exhibits, the defense is resting its case.

WHEREFORE, premises considered, it is most respectfully prayed to

this Honorable Court that the foregoing documentary exhibits be admitted

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for all purposes for which each and all said exhibits were being offered in
proving the claims of the complainant/s, and with the formal submission of
the aforesaid exhibits coupled with the testimonies of the witnesses who
testified thereon.

Quezon City, Metro Manila

March 10, 2019

ATTY. REJOUREL CHRISTIAN ADOBO

Counsel for Plaintiff

NOTICE

The Hon Clerk of Court

RTC Branch 28 Quezon City

GREETINGS:

Please submit the foregoing Formal Offer for the consideration and
approval of the Honorable Court immediately upon receipt hereof.

ATTY. REJOUREL CHRISTIAN ADOBO

Counsel for
Plaintiff

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 EXPLAINATION OF SERVICE

Copies of the foregoing Formal Offer are served upon counsel of the
petitioner Jose Marie “Vice Ganda” Viceral and filed with the Court by
personal service.

MONJE, ADOBO, BALABAT (MBA) LAW

OFFICES
Counsel for Petitioner Jose Marie “Vice
Ganda” Borja Viceral
3/F Trade & Industry Building
361 West Avenue, Quezon City
Tel. No. (02) 889 - 6792

Filed by:

ATTY. REJOUREL CHRISTIAN ADOBO

COUNSEL FOR PLAINTIFF

Copy furnished:

Regional Trial Court

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Branch 28
Quezon City

Calantoc Loyola Law (CLaw) Offices

Counsel for Oppositor
9/F CitiBank Centre
8741 Paseo de Roxas, Taguig City,
Metro Manila
Tel. No. (02) 810-82-12
Email: clawoffices@claw.com.ph

AFFIDAVIT OF SERVICE BY REGISTERED MAIL

I, Rodrigo I. Dumede, of legal age and having been duly sworn depose and say:

That I am the messenger of Attys. MONJE, ADOBO, BALABAT (MBA) LAW

OFFICES, counsels for Petitioner in the case entitled “Jose Marie “Vice Ganda” Borja Viceral
vs. Charles Dantes Smith, Sp. Proc. No. 08-2018 In Re: Petition for Guardianship”, and as such
messenger I served upon the counsels of the adverse party, the petition filed in said case:

By depositing the copy in the post office in sealed envelope, plainly addressed to the
counsels at their office, with postage fully prepaid, and with instruction to the postmaster to
return the mail to the sender after ten days if undelivered, this 10th day of March 2019, as shown
by Registry No. 12345 dated 10 March 2019 of the post office of Quezon City.

IN WITNESS WHEREOF, I have signed this affidavit this 10th day of March 2019 at
Quezon City.

(SGD.) RODRIGO I. DUMEDE

Affiant

SUBSCRIBED AND SWORN to before me on this 10th day of March 2019 at Quezon City,
affiant exhibiting to me his Driver's License No. 12345852515 which will expire on April 26,
2020.

(SGD.) LIAR GADON

Notary Public
Quezon City

Doc. No. _______;

Page No. _______;
Book No. _______;
Series of 2018.

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