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    Pre-Trial Brief

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    Budz Marata
    This document is a pre-trial brief submitted by petitioner's counsel in a case for nullification of marriage. It summarizes that the petitioner alleges the marriage should be annulled because the respondent has a psychological incapacity of narcissistic personality disorder that existed prior to the marriage. It lists witnesses and evidence to be presented, including a psychologist who evaluated the respondent. The main issue is whether the respondent's condition is grounds for annulling the marriage under Article 36 of the Family Code.

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    Pre-Trial Brief

    Uploaded by

    Budz Marata
    49 views3 pages
    This document is a pre-trial brief submitted by petitioner's counsel in a case for nullification of marriage. It summarizes that the petitioner alleges the marriage should be annulled because the respondent has a psychological incapacity of narcissistic personality disorder that existed prior to the marriage. It lists witnesses and evidence to be presented, including a psychologist who evaluated the respondent. The main issue is whether the respondent's condition is grounds for annulling the marriage under Article 36 of the Family Code.

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    Pre-trial Brief

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    This document is a pre-trial brief submitted by petitioner's counsel in a case for nullification of marriage. It summarizes that the petitioner alleges the marriage should be annulled because the respondent has a psychological incapacity of narcissistic personality disorder that existed prior to the marriage. It lists witnesses and evidence to be presented, including a psychologist who evaluated the respondent. The main issue is whether the respondent's condition is grounds for annulling the marriage under Article 36 of the Family Code.

    Copyright:

    © All Rights Reserved
    Download as DOC, PDF, TXT or read online from Scribd
    Download as doc, pdf, or txt
    49 views3 pages

    Pre-Trial Brief

    Uploaded by

    Budz Marata
    This document is a pre-trial brief submitted by petitioner's counsel in a case for nullification of marriage. It summarizes that the petitioner alleges the marriage should be annulled because the respondent has a psychological incapacity of narcissistic personality disorder that existed prior to the marriage. It lists witnesses and evidence to be presented, including a psychologist who evaluated the respondent. The main issue is whether the respondent's condition is grounds for annulling the marriage under Article 36 of the Family Code.

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    © All Rights Reserved
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    Republic of the Philippines

    REGIONAL TRIAL COURT


    National Capital Judicial Region
    Makati City
    Branch 1

    LIGAYA N. DE GUZMAN
    Petitioner,

    - versus - Civil Case No. 92851


    For: Declaration of Nullity of Marriage

    RONALD B. DE GUZMAN,
    Respondent,
    x----------------------x

    PRE-TRIAL BRIEF

    PETITIONER by the undersigned counsel and unto this Honorable Court most
    respectfully states:

    STATEMENT OF THE FACTS AND OF THE CASE

    This is an action for Declaration of Nullity of Marriage under Articles 36 and 68


    of the New Family Code.

    Petitioner alleges in her Petition, viz: a) that petitioner and respondent are
    husband and wife; b) that respondent is clinically found to be psychologically
    incapacitated to comply with the essential requisites of marriage identified as
    Narcissistic Personality Disorder; c) that the root cause of such illness is traced from
    their respective childhood; d) such illness is diagnosed to be grave and incurable; e)
    that such illness existed prior to the marriage and became apparent at the time of the
    marriage.

    Petitioner likewise alleges that a child was born in wedlock and their de-facto
    separation which culminated from petitioner’s frustration of respondent’s mercurial
    change of disposition, abusive and manipulative conduct, immaturity, excessive
    spending and adulterous conduct. That respondent failed to give love, emotional
    support and fidelity to the marriage.

    PROPOSED STIPULATION OF FACTS

    1. The identity of parties as petitioner and respondent;


    2. The fact of marriage, parties having been married on July 31, 2013 ;
    3. The a child was born in wedlock;
    4. The no property was acquired by both spouses;
    5. Their de-facto separation between the spouses;
    6. The respondent’s failure to love petitioner;
    7. The respondent’s failure to support their child;
    8. The respondent’s acts of infidelity

    LIST OF DOCUMENTARY EVIDENCE

    1. Marriage Certificate ----Exhibit "A"


    2. Birth Certificate of child-----Exhibit "B"
    3. The Psychological Report-----Exhibit "C”
    ABSTRACT OF TESTIMONIES

    Petitioner will be testifying on the allegations in the Petition and will present
    documentary evidence.

    The Clinical Psychologist who will testify on the psychological evaluation done
    on respondent.

    NUMBER OF WITNESSES TO BE PRESENTED

    Petitioner and at least three (3) witnesses.

    ADMISSIONS

    Outside of the matters alleged, petitioner is not inclined to admit further


    matters.

    APPLICABLE LAWS AND JURISPRUDENCE

    Provisions on the Family Code.

    ISSUES

    Whether or not respondent is psychologically incapacitated to comply with the


    essential requisites of marriage which is a valid ground under Art. 36 of the New
    Family Code to declare the marriage a nullity.

    AVAILABILITY FOR TRIAL

    Counsel will be available for trial on dates convenient with this Honorable Court.

    Respectfully Submitted:

    Makati City. October 28, 2019.

    Atty. YZA MARIE T. MENDIOLA


    Counsel for Petitioner
    20f Citi Tower, Valero Street
    Brgy. Bel-air, Makati City
    IBP No. 83843 dtd. 06-15-12 Makati City
    PTR No. 6453722 / 06/15/12/ Makati
    Roll No. 42842
    MCLE Compliance II – 0008392
    Dtd. March 27, 2019

    Atty. LOISY JUGUAN


    Counsel for Petitioner
    20f Citi Tower, Valero Street
    Brgy. Bel-air, Makati City
    IBP No. 83957 dtd. 09-15-12 Makati City
    PTR No. 6453982 / 09/15/12/ Makati
    Roll No. 42909
    MCLE Compliance II – 0008587
    Dtd. August 27, 2019

    Atty. JOB BUDS M. MARATA


    Counsel for Petitioner
    20f Citi Tower, Valero Street
    Brgy. Bel-air, Makati City
    IBP No. 83035 dtd. 09-15-10 Makati City
    PTR No. 6451865 / 09/15/10/ Makati
    Roll No. 42645
    MCLE Compliance II – 0008112
    Dtd. July 11, 2019

    Copy furnished:
    Office of the City Prosecutor ------------------- Personal Service
    Quezon City

    Office of the Solicitor General ----------Registered Mail w/ Return Card


    135 Amorsolo St., Legaspi Vill.,
    Makati City

    EXPLANATION

    Pursuant to the Provision of Rule 13, Section 11 of the 1997 Rules in Civil Procedure as Amended,
    undersigned submits this Explanation that the service of this Pre- Trial was to Office of the Solicitor General
    by Registered Mail instead of personal serve in view of lack of manpower.

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