Republic of the Philippines

REGIONAL TRIAL COURT

First Judicial Region
Branch 25
Labrador, Davao City

EDWARD WILLIAMS,
Petitioner, Civil Case No. 11291204
For: Declaration of Nullity
of Marriage under Art. 36
-versus- of the Family Code

PAIGE MORGAN
Respondent,

x------------------------------------x

JUDICIAL AFFIDAVIT
Of the petitioner EDWARD WILLIAMS
(in lieu of his Direct Testimony)

PRELIMINARY STATEMENT

The person examining me is Atty. Abo G. Gado with law office

address at 143 Kisad Road, Baguio City. My Judicial Affidavit is being
taken at the above-mentioned place in the presence of Victor A. Magtanggol,
the office staff. The questions are asked in the English language which I
speak and fully understand and I am answering the questions fully conscious
that I do so under oath and I am aware that I may face criminal liability for
false testimony or perjury for any false statement or statements made or
given by me.

ATTY. ABO G. GADO

Representing the
LAW FIRM OF LEGAL LEGENDS
Counsel for the Petitioner

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 OFFER OF TESTIMONY OF WITNESS

The testimony of petitioner, EDWARD WILLIAMS, is being offered

to prove the following:

1. That the petitioner and respondent, Paige Morgan, are lawfully

married as evidenced by their Certificate of Marriage issued by the
National Statistics Office (NSO);

2. That both petitioner and respondent are of legal age, Filipino and
residents of Labrador, Davao City, Philippines;

3. That they were blessed with three (3) children, namely Sorren
Williams, Arabella Williams, and Prince Williams;

4. That two of the children, namely Arabella and Prince, are minors;

5. That the parties own a conjugal property located at Session Road,

Davao City;

6. That the parties owned a car, 1998 BK Pajero, which was later on sold
to pay off the conjugal property in Session Road, Davao City;

7. That respondent conceived a child out of her illicit relationship as

evidenced by a NSO Birth Certificate;

8. That respondent failed to perform the essential responsibilities of a

parent to her children, and a wife to her husband;

9. Petitioner asks this Honorable Court to declare his marriage to

respondent null and void on the ground of respondent’s psychological
incapacity in accordance with the provisions in Articles 36, 68, 70, 72,
and 220 of the Family Code;

10.Petitioner would likewise identify the following:

EXHIBIT DOCUMENT
A Certificate of Marriage dated April 25, 1996 issued
by the National Statistics Office (NSO).
B Birth Certificate of Sorren Williams dated December
10, 1996 issued by the National Statistics Office
(NSO).
C Birth Certificate of Arabella Williams dated
December 21, 1999 issued by the National Statistics
Office (NSO).
D Birth Certificate of Prince Williams dated August 30,
2004 issued by the National Statistics Office (NSO).
E Birth Certificate of the child of Paige with her
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 paramour issued by the National Statistics Office
(NSO).
F Contract of Sale for the Session Road, Davao City
house and lot
G Collated Receipts for the money Edward Williams.
sent
H Certificate of Registration of 1998 BK Pajero
J Deed of Sale of the 1998 BK Pajero

13. In addition, the petitioner will identify his Judicial Affidavit that he
executed and identify the signature in every page of said Judicial
Affidavit as his own signature, and that the Judicial Affidavit be part of
his oral testimony.

14. Finally, the testimony of the petitioner is being offered as his Direct
Testimony in this case.

QUESTIONS AND ANSWERS

1. Question (Q): Kindly state your name, address and other personal
circumstances.

Answer (A): My name is Edward Williams, of legal age, Filipino

citizen and I am a resident of Labrador, Davao City here in the
Philippines.

2. Q: What is your involvement in the case ?

A: I am the petitioner for the Declaration of Nullity of Marriage
against respondent, Paige Morgan.

3. Q: How do you know the respondent?

A: She is my wife. We are husband and wife as recorded in a
Certificate of Marriage, Ma’am.

4. Q: Mr. Williams, I am showing to you a Certificate of Marriage issued

by the NSO, dated April 25, 1996 and marked as “Annex A”. Does
this have a relation to the one you are talking about?
A: Yes ma’am. That is the Certificate of Marriage I was talking about.

5. Q: Kindly narrate to us the events that transpired which led you to file
this action.
A: Paige and I are sweethearts before we got married. We were
engaging in premarital sex then, Paige conceived our first child,

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 Sorren Williams. He was born on December 10, 1996. His birth
certificate was issued by the NSO.

6. Q: Mr. Williams, I am showing to you a Birth Certificate issued by

the NSO and marked as “Annex B”. Does this have a relation to the
birth certificate you were talking about?
A: Yes. That is Sorren Williams’ birth certificate and the one I was
talking about.

7. Q: What happened next?

A: I married Paige to save Sorren from being born as a bastard
because we were not married at the time Sorren was conceived.

8. Q: And then?
A: Paige and I were married in Labrador, Davao City. We were issued
a Marriage Certificate for the wedding which I talked about earlier.

9. Q: What happened next?

A: I tried to convince Paige to find a decent and stable job because she
was physically and mentally capable of being employed, but Paige
refused and preferred to hang out with her friends from sunrise to
sunset as if she is still single. There were times that she would go
home drunk, either late at night or early in the morning. That was
before I went to work in Copenhagen, Denmark.

10.Q: Why and when did you leave for Denmark?

A: I decided to work abroad for my family to have a better future. I
worked as an OFW in Denmark in 1999. At the time I left, Paige was
pregnant with our second child, Arabella. She was born on December
21, 1999. Her birth certificate was also issued by the NSO.

11.Q: Mr. Williams, I am showing to you a Birth Certificate issued by

the NSO and marked as “Annex C”. Does this have a relation to the
birth certificate that you were talking about?
A: Yes, that is the birth certificate that I was talking about.

12.Q: What happened next?

A: In the year 2000, I heard rumors from my relatives that Paige was
having an illicit relationship with another man and that she was
bringing men in our house to have some drinking sessions.

13.Q: And then, what happened?

A: I came back to the Philippines in 2001. And I asked Paige if the
rumors were true about her having an illicit relationship with another

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 man, and at the same time bringing home men in our house for
drinking sessions. Paige said that the rumors were not true so I
believed her.

14.Q: What happened next?

A: We had another child, ma’am, during my stay here in the
Philippines. We had Prince. Her birth certificate was also issued by
the NSO.

15.Q: Mr. Williams, I am showing to you a Birth Certificate issued by

the NSO and marked as “Annex D”. Does this have a relation to the
birth certificate that you were talking about?
A: Yes Ma’am. That is Prince’s Birth Certificate and the one I was
talking about earlier.

16.Q: What happened after that?

A: I went to Sweden to work. While I was there, I heard rumors that
Paige is having an illicit relationship again and that our children were
left either with my family or Paige’s family , instead of her caring and
giving love and affection to them.

17.Q: Did you believe this rumors?

A: No, ma’am. Rumors are just rumors.

18.Q: What happened then?

A: Around 2006, while I was still in Sweden, I came to know that
Paige bought a house and lot in Session Road, Davao City which was
worth One million three hundred fifty thousand pesos (Php 1,
350,000.00). It was only after the negotiation between Paige and the
owner of the house was formally executed through a contract that
Paige told me about it.

19.Q: Mr. Williams, I am showing to you a contract of sale marked as

“Annex F”. What does this document have in relation to the contract
you were talking about?
A: That is the contract I was talking about.

20.Q: What are the circumstances of this contract?

A: The sale of the house and lot to Paige was without my knowledge
and consent. What was negotiated between Paige and the owner was
that the amount of Two Hundred thousand pesos (Php 200,000.00)
was for down payment and that there would be monthly amortizations
in the amount of Fifty Thousand pesos (Php 50,000.00).

21.Q: What happened next?

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 A: I had no option but to send the amount of Two hundred thousand
pesos (Php 200,000.00) for the down payment of the said house and
lot. I also sent amounts for the monthly amortizations, but I sent more
than Fifty Thousand pesos (Php 50,000.00) for the amortizations with
the agreement that I had with Paige that any excess will be spent for
the allowance of my children and Paige, as she was jobless. These
amounts are proved by receipts.

22.Q: Mr. Williams, you said that the amounts are proven by receipts. I
am showing to you receipts for certain amounts, all collated and
marked as “Annex G”. Do these receipts have a relation to the ones
you were talking about?
A: Yes, those are the receipts I have for the amounts I sent.

23.Q: What happened next?

A: After some time, I called Paige to ask if the house and lot was
already fully paid. She told me only Seven Hundred Thousand Pesos
(Php 700,000.00) was paid.

24.Q: Did you ask her why only such amount was paid?
A: No, I did not.

25.Q: What did you do then?

A: I decided to sell our car, 1998 Bk Pajero, evidenced by Certificate
of Registration with the Land Transportation Office(LTO) to pay off
the unpaid amortizations and avoid penalties.

26.Q: Mr. Williams, I am showing to you a Certificate of Registration

marked as “Annex H”. Does this certificate have a relation to the one
that you were talking about?
A: Yes, that is the certificate I was talking about.

27.Q: Were you able to sell the said car?

A: Yes, a buyer bought the car for Five Hundred Thousand Pesos
(Php 500,000.00) as evidenced by a Deed of Sale.

28.Q: Mr. Williams, I am showing to you a Deed of Sale marked as

“Annex J”. Does this have a relation to the deed that you were talking
about?
A: Yes, that is the same deed of sale that I was talking about.

Page 6 of 11
29.Q: From the sale of the car, were you able to pay off the said
amortizations?
A: No, Paige still failed to pay.

30.Q: What happened next?

A: I received a call from my relatives that Paige is still continuing her
illicit relationship with another man and at the same time, she was still
bringing home men in our house for drinking session.

31.Q: Did you do anything after that?

A: Yes. I confronted Paige about it through a long distance call.

32.Q: What transpired during the call?

A: I asked Paige if she was having an affair with another man and she
answered yes. I was so upset and frustrated, so I asked her other
questions, especially about the rumors I heard before.

33.Q: What did you ask her and what did she tell you?
A: I asked her when did her illicit relationship start and she said it’s
been a long time already. I asked her about bringing home men and
about the drinking sessions instead of taking care of our children, and
she said yes.

34.Q: What else?

A: I asked her if she never gave the attention, love, affection, support,
and help that a mother should give to her children. Paige cried and
asked forgiveness for her irresponsibility, laziness, immaturity,
infidelity and for her total failure to comply with her essential
obligations and responsibilities as a mother and wife.

35.Q: Did you ask her more questions?

A: Yes. I asked her if she spent all her time with her barkadas and
paramour instead of looking after our children, and she admitted. I
also asked her if the house and lot in Session Road, Davao City was
already paid and she answered no.

36.Q: Did she tell why the house and lot was not fully paid?
A: Yes. She made a confession that the house and lot in Session Road,
Davao City was not fully paid because she had been using the money
sent by me to support her illicit affair and spending it on her friends
and personal needs. She also confessed that the amount paid for the
car was used by her to support her illicit relationship instead of paying
the remaining balance.

Page 7 of 11
37.Q: What happened next?
A: I paid the remaining balance for the house and lot in Session Road,
Davao City.

38.Q: After that, what happened?

A: Our relationship turned sour and it worsened because Paige went to
work in London without my knowledge and consent. She said she got
the money in processing all her documents and her fare going to
London from a certain Atty. Stephen. I did not ask any further.
39.Q: What happened next?
A: I heard a rumor and I confronted her about it.

40.Q: What rumor was that?

A: That she had a child with her paramour. I took hold of a copy of
the birth certificate of the child.

41.Q: Mr. Williams, I am showing to you a birth certificate issued by the

NSO and marked as “Annex E”. Does this have a relation to the birth
certificate you were talking about?
A: Yes, That is the same birth certificate I was talking about.

42.Q: What happened next?

A: Instead of trying to regain our trust and to cope up with her
shortcomings, Paige forgot about our family and her essential marital
obligations and decided to leave me and our children.

43.Q: Has she tried to communicate with you and talk about your
relationship?
A: No. She has and up to now shows no remorse for her acts of
infidelity, immaturity, irresponsibility, her extravagant lifestyle, her
being a cheater, a liar and a drunkard.

44. Q: How are you affected by the events surrounding your marriage?
A: During the circumstances that I narrated, I firmly felt and knew
that I was tired with all the infidelity, foolishness, irresponsibility,
immaturity, extravagance, and immaturity of my wife. I realized that I
did not only made a wrong decision. I married her just because I
impregnated her, but I also married a woman who does not understand
her marital obligations and was incapacitated to take care and support
our children.

45.Q: Do you remember having executed a Judicial Affidavit in relation

to this case?
A: Yes.

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 46.Q: If this Judicial Affidavit is shown to you, will you be able to
identify it?
A: Yes ma’am.

47.Q: I am now showing to you this Judicial Affidavit executed on May

21, 2020, will you tell me what relation does this document have to
the Judicial Affidavit which you said you executed?
A: This is the same Judicial Affidavit that I executed.

48.Q: In this Judicial Affidavit, is the signature above the name Edward
Williams on page nine (9) your signature?
A: Yes, that is my signature.

49.Q: Under your present oath, do you confirm and affirm that this
Judicial Affidavit contains the whole truth nothing but the truth?
A: Yes, I do.

50.Q: Do you have something to add, change or remove from this

Judicial Affidavit?
A: None, ma’am.

IN WITNESS WHEREOF, I have hereunto set my hand this 21st day

of May at Baguio City, Philippines.

EDWARD WILLIAMS.
Affiant
PDL No. 123456
Expires: 2022/11/29

SUBSCRIBED AND SWORN to before me this 21st day of May at

Baguio City, Philippines, affiant exhibiting to me his competent evidence of
identity as shown above. Affiant is known to me through competent
documents to be the same person who executed the foregoing and
acknowledge that the same is their voluntary act and deed.

Doc. No. 09 Atty. Abo G. Gado

Page No. 09 Notary Public in the City of Baguio
Book No. 09 until 31 December 2022
Series of 2020 PTR No. ; 67485; 11/06/2000
IBP No.: 26585; 10/07/2000
Roll No. 33785; 10/06/2000
MCLE Compliance No. 222222;
11/6/2001

Page 9 of 11
 SWORN ATTESTATION

I, Atty. Abo G. Gado, of legal age, Filipino, single, with office

address at 143 Kisad Road, Baguio City, Philippines, under oath, hereby
depose and say:

That I am the lawyer who conducted the examination by way of

question and answer format on the petitioner, Edward Williams; that I
faithfully recorded or caused to be recorded the questions I asked and the
corresponding answers that the petitioner gave; that neither the undersigned
nor any person or persons then present or assisting the petitioner coached
him regarding his answers; and that the answers were voluntarily and freely
made by the petitioner.

IN WITNESS WHEREOF, I have hereunto set my hand this 21st day

of May in Baguio City, Philippines.

Atty. Abo G. Gado

Affiant
IBP I.D 726585; 10/07/2000
Roll No. 3785

SUBSCRIBED AND SWORN to before me this 21st day of May in

Baguio City, Philippines. Affiant personally came and appeared with valid
government identification issued by the Integrated Bar of the Philippines,
bearing the Lawyer’s Roll No. 3785; 09/06/2000; Baguio City, photograph
and signature known to me as the same person who personally signed the
foregoing instrument before me and avowed under penalty of law to the
whole truth of its contents of his attestation.

Doc. No. 09 Atty. Nota Rio N. Ako

Page No. 10 Notary Public in the City of Baguio
Book No. 09 until 31 December 2022
Series of 2020 PTR No. ; 83546; 09/12/2000
IBP No.: 789012; 11/08/2000
Roll No. 8888; 08/08/2000
MCLE Compliance No. 54; 10/1/2001
Rm. 09 Laperal Building,
Baguio City

Copy Furnished:
THE PROSECUTOR’S OFFICE
Justice Hall
Labrador, Davao City

THE SOLICITOR GENERAL

Office of the Solicitor General
Page 10 of 11
134 Amorsolo Street
Legaspi Village
1229 Makati, Philippines

EXPLANATION

Service of a copy of the foregoing Petition to the Office of the

Solicitor General was done through registered mail due to distance and lack
of manpower which renders personal service impracticable

Atty. Abo G. Gado

Republic of the Philippines)
City of Baguio)s.s

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