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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT


6TH JUDICIAL REGION
BRANCH __
ILOILO CITY

MARIA ELLEN ADARNA, Civil Case No. ________


Plaintiff FOR: ANNULMENT OF
MARRIAGE

- versus –

JOHN LLOYD CRUZ,


Defendant
X-------------------X

FORMAL OFFER OF EVIDENCE


Petitioner, through counsel, unto this Honorable Court, most respectfully
offers the following pieces of evidence, to wit:
EXHIBITS DESCRIPTION PURPOSE/S
“A”
Petition To prove that the
Honorable Court acquired
jurisdiction over the
petition and subject matter
“A1” of the petition.

Marriage Certificate To prove that there is a


valid and existing marriage
between the petitioner and
the respondent.
“A2”
Birth Certificate of John To prove that petitioner
Allen Dela Cruz and respondent have
children.
“A3”
Birth Certificate of Lloyda To prove that petitioner
Marie Dela Cruz and respondent have
children.

“B”
Summons To prove that the
respondent has been
summoned and served a
copy of the petition
“B1” Sheriff’s Return together with its annexes
and has been notified of
the proceeding. Notice of Appearance To prove that the Office of
“C” OSG the Solicitor General has
been furnished with a copy
Deputation of the petition.
“D”

Answer of the Respondent


“E”

Reply by the Petitioner


“F”

To prove that there is a


Psychological Report condition of psychological
“G” incapacity on the part of
the respondent which
prevents her from
performing her duties and
responsibilities as wife to
the petitioner.

Judicial Affidavit of the To prove that the


“H” Petitioner respondent is
psychologically
incapacitated under Art. 36
of the Family Code to
Signature of the Petitioner
comply with her marital
“H1”
obligations. Likewise,
these are being offered as
part of the direct testimony
of the petitioner and to
prove the material and
relevant circumstances in
this case.

“I” Judicial Affidavit of Dr.


Belo To prove that a clinical
identification of the root
causes, antecedence,
Signature of Dr. Belo gravity and incurability of
“I1” the psychological
incapacity of respondent to
perform her essential
marital obligations has been made and that it was found that this is in the form of a mental
disorder considered to be grave, severe, long lasting and incurable by any treatment available.
These are also being offered as part of the direct testimony of the expert witness.

RESPECTFULLY SUBMITTED.

WHEREFORE, it is most respectfully prayed unto this Honorable Court that


the above- mentioned pieces of evidence be ADMITTED.

Other just and equitable reliefs are also prayed for.

Iloilo City, Philippines, February 12, 2018.

ATTY. LOUISE MIKHAELA ROSE L. ESCARRILLA


Counsel for Plaintiff
Escarrilla, Toralde, Cabantud Law Office, Jaro, Iloilo City
Roll of Attorney No. 12345
PTR No. 0416909, 05/10/17, Iloilo City
IBP No. 12345, 05/02/17, Iloilo City
MCLE Comp. No. XX- 0001993
NOTICE
The Honorable Clerk of Court
RTC Branch __ Iloilo City

GREETINGS:

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

ATTY. LOUISE MIKHAELA ROSE L. ESCARRILLA


Counsel for Plaintiff

Copy furnished:

Counsel for the Defendant

EXPLANATION

Copies of the foregoing Formal Offer are served upon counsel of the
defendant and filed with the Court by personal service.

ATTY. LOUISE MIKHAELA ROSE L. ESCARRILLA


Counsel for Plaintiff