REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

NATIONAL CAPITAL JUDICIAL REGION
MAKATI CITY, BRANCH 58

JUAN P. DELA CRUZ

Petitioner,

Civil Case No. R – MKT -

-versus- 17 – 11900 – CV
FOR: Declaration of
Nullity of Marriage under
Article 36 of the Family
Code
MARIA B. DELA CRUZ
Respondent.
X-------------------------------X

FORMAL OFFER OF EVIDENCE

Petitioner, through counsel, unto this Honorable Court,

most respectfully offers the following pieces of evidence, to
wit:

EXHIBIT NATURE PURPOSE

“A” Residence Certificate To prove the current

“A-1” Signature of the Makati
City Treasurer on the
Residence Certificate of the
Petitioner
“B” Marriage Certificate
“B-1” Signature of the Makati
City Civil Registrar on the
Marriage Certificate
“B-2” Signature of the
Solemnizing Officer on the
Marriage Certificate
residence of the
Petitioner.
To prove the current
residence of the
Petitioner.
To prove that there is
a valid and existing
marriage between the
Petitioner and
Respondent.
To prove that there is
a valid and existing
marriage between the
Petitioner and
Respondent.
To prove that there is
a valid and existing
marriage between the
Petitioner and
Respondent.
“B-3” Signature of Edwin
Buenaventura, Sr.
“B-4” Signature of Maria
Florentina Tapel
“C” Birth Certificate of Sophia
B. Dela Cruz
“C-1” Dr. De Guzman’s College
Diploma on his Bachelor’s
Degree on Psychology
“C-2” Licensure Degree on
Psychology
“C-3” Licensure Degree on
Medicine
“C-4” Dr. De Guzman’s Master’s
Degree Diploma on Medical
Humanities and Bioethics
“C-5” Dr. De Guzman’s Master’s
Degree Diploma on Health
Administration
“C-6” Diploma on Dr. De
Guzman’s Bachelor’s
Degree of Law
“C-7” Doctorate Degree on
Philosophy of Dr. De
Guzman
“C-8” Signature of the Attending
Midwife on the Birth
Certificate of Sophia B.
Dela Cruz
“C-9” Signature of the
Administrative Secretary of
Rizal Medical Center, Pasig
City on the Birth Certificate
of Sophia B. Dela Cruz
“C-10” Signature of the
Administrative and Civil
Registrar General of Pasig
City on the Birth Certificate
of Sophia B. Dela Cruz
To prove that there is
a competent witness
on the valid and
existing marriage of
the Petitioner and
Respondent.
To prove that there is
a competent witness
on the valid and
existing marriage of
the Petitioner and
Respondent.
To prove that
Petitioner and
Respondent had a
child.
To prove his identity
as an Expert Witness.
To prove his identity
as an Expert Witness.
To prove his identity
as an Expert Witness.
To prove his identity
as an Expert Witness.
To prove his identity
as an Expert Witness.
To prove his identity
as an Expert Witness.
To prove his identity
as an Expert Witness.
To prove that
Petitioner and
Respondent had a
child.
To prove that
Petitioner and
Respondent had a
child.
To prove that
Petitioner and
Respondent had a
child.
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“D” Neuro-Psychiatric To prove that there is
Evaluation Report on Juan a condition of
P. Dela Cruz Psychological
Incapacity on the part
of the Petitioner which
prevents him from
performing his
essential marital
obligations as
husband to the
Respondent and his
duties and
responsibilities as a
father to their child.
“E” Neuro-Psychiatric To prove that there is
Evaluation Report on Maria a condition of
B. Dela Cruz Psychological
Incapacity on the part
of the Respondent
which prevents her
from performing her
essential marital
obligations as wife to
the Petitioner and her
duties and
responsibilities as a
mother to their child.
“E-1” Signature of Dr. Peejay T. To prove that there is
De Guzman on the Neuro- a condition of
Psychiatric Evaluation Psychological
Report of Juan P. Dela Incapacity on the part
Cruz and Maria B. Dela of the Respondent
Cruz which prevents her
from performing her
essential marital
obligations as wife to
the Petitioner and her
duties and
responsibilities as a
mother to their child.
“F” College Diploma of the To prove that
Petitioner Petitioner earned his
degree different from
the achievements
earned by the
Respondent being a
career woman.
“G” Certificate of Employment To prove that
of the Petitioner dated 12 Petitioner has a
May 2007 different level of
status in life

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 compared to the
Respondent.
“H” Certificate of Employment To prove that
of the Petitioner dated 12 Petitioner has a
January 2008 different level of
status in life
compared to the
Respondent.
“I” Original Petition dated 12 To prove that the
October 2019 Petitioner filed this
Petition for the
Declaration of Nullity
of Marriage; To further
prove compliance with
the Jurisdictional
Requirements.
“J” Order and Notice of To prove that the
Hearing dated 18 October Honorable Court
2019 issued an Order for
the publication of the
Petition in the Official
Gazette and posting of
the said Order in
places mentioned
therein and furnishing
Government Agencies
and persons
mentioned in that
Order; To further
prove compliance with
the Jurisdictional
Requirements.
“K” Summons To prove that the
Respondent has been
summoned and served
a copy of the Petition
together with its
annexes and had been
notified of the
proceeding.
“L” Sheriff’s Return dated 20 To prove that the
October 2019 Respondent has been
summoned and served
a copy of the Petition
together with its
annexes and had been
notified of the
proceeding.
“M” Proof of Service/ Stamp To prove that the
Receipt on the Office of the Office of the Solicitor
Solicitor General General received a

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 copy of the 18 October
2019 Order and
Notice of Hearing of
the Honorable Court;
To prove compliance
with the Jurisdictional
Requirements.
“N” Certificate of Posting dated To prove that the
12 November 2019 Order dated 18
October 2019 was
posted in the places
mentioned in the said
Order; To further
prove compliance with
the Jurisdictional
Requirements.
“O” Entry of Appearance by the To prove that the OSG
Office of the Solicitor received the Order
General (OSG) dated 15 and Notice of Hearing
November 2019 dated 18 October
2019; To further prove
compliance with the
Jurisdictional
Requirements.
“P” Deputation Letter dated 15 To prove that the OSG
November 2019 has deputized the City
Prosecutor’s Office of
Makati City to appear
in this case for and in
its behalf; To further
prove compliance with
the Jurisdictional
Requirements.
“Q” Original Official Gazette To prove that the
dated 05 November 2019 Order and Notice of
Hearing dated 12
October 2019 was
published in the
Official Gazette in its
issue dated 05
November 2019; To
further prove
compliance with the
Jurisdictional
Requirements.
“R” Page 1 of the said Official To prove that the
Gazette where the Order Order and Notice of
and Notice of Hearing was Hearing dated 12
published October 2019 was
published in the
Official Gazette in its

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 issue dated 05
November 2019; To
further prove
compliance with the
Jurisdictional
Requirements.
“S” Certificate of Publication To prove that the
dated 05 November 2019 Order and Notice of
Hearing dated 12
October 2019 was
published in the
Official Gazette in its
issue dated 05
November 2019; To
further prove
compliance with the
Jurisdictional
Requirements.
“T” Judicial Affidavit of Dr. To prove that a
Peejay T. De Guzman clinical identification
of the root causes,
antecedence, gravity
and incurability of the
psychological
incapacity of
respondent to perform
his essential marital
obligations has been
made and that it was
found that this is in
the form of a 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.
“T-1” Signature of Dr. Peejay T. To prove his identity
De Guzman on the Judicial as an Expert Witness.
Affidavit
“T-2” Identification Card To prove his identity
(Licensed Physician) of Dr. as an Expert Witness.
De Guzman
“T-3” Identification Card To prove his identity
(Licensed Clinical as an Expert Witness.
Psychologist) of Dr. De
Guzman

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 “T-4” Signature of Dr. Peejay T.
De Guzman on the Neuro-
Psychiatric Evaluation of
Petitioner
“T-5” Signature of Dr. Peejay T.
De Guzman on the Neuro-
Psychiatric Evaluation of
Respondent
“U” Collusion Investigation
Report of the Office of the
Solicitor General (OSG)
To prove his identity
as an Expert Witness.
To prove his identity
as an Expert Witness.
To prove that no
connivance is existing
between the Petitioner
and Respondent to
declare the nullity of
their marriage based
on Article 36 of the
Family Code.

Respectfully Submitted.

WHEREFORE, it is most respectfully prayed unto this

Honorable Court that the above-mentioned pieces of evidence
be ADMITTED.

Other reliefs, just and equitable under the

circumstances, are likewise prayed for.

Makati City, 13 January 2020.

ATTY. ADRIANNE MAE M. ABADILLA

Counsel for the Petitioner
Ground Floor, Manere Bldg. I, V-Luna Corner
Matahimik St., Diliman, Quezon City
Attorney’s Roll No. 66666
PTR No.5612336C/1-9-20/Quezon City
IBP No. AR001262/1-9-20/Quezon City
MCLE Exempt per MCLE Governing Board Order No. 1, s.
2008

EXPLANATION
(Pursuant to Sec. 11, Rule 13 of the 1997 Rules of Civil
Procedure)

This Formal Offer of Evidence is being served by

Registered Mail, Personal Service being impractical on
account of the distance, heavy vehicular traffic and lack of
available messenger/staff at this time.

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 ATTY. ADRIANNE MAE M. ABADILLA

Copy furnished:

Atty. Arman Hernando

Counsel for the Respondent
Unit 123 City & Land Mega Plaza,
ABC Ave. cor. Garnet Road,
Ortigas Center, Pasig City 1600

Office of the Solicitor General

134 Amorsolo St., Legazpi Village,
1229 Makati City,
Tel. No. (02) 988-1674

Office of the City Prosecutor

16F Makati City Hall (New Bldg.),
JP Rizal, Brgy. Poblacion,
Makati City

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