Republic of the Philippines

REGIONAL TRIAL COURT

National Capital Judicial Region
Makati City
Branch 1

LIGAYA N. DE GUZMAN
Petitioner,

Civil Case No. 92851

Versus- For: Declaration of Nullity of
Marriage

RONALD B. DE GUZMAN
Respondent.
X ------------------------------------- X

FORMAL OFFER OF EVIDENCE

Respondent, through counsels, unto this Honorable Court, most

respectfully offers the following pieces of evidence, to wit:

EXHIBIT 1 Contract to Sell of the One-Bedroom Condominium

Unit
in Chateau Elysee located at Better Living
Subdivision,
Paranaque City, entered between SM Development
Corporation and Ronal B. De Guzman
EXHIBIT 1-A Signature of Ronald B. De Guzman
EXHIBIT 2 Contract of Loan Agreement with Real Estate
Mortgage
between BPI Family Savings Bank and Ronald B. De
Guzman
EXHIBIT 2-A Signature of Ronald B. De Guzman

PURPOSES: These documents are being offered to form part

of the testimony of the respondent and to prove that he bought a condominium
unit at pre-selling as a gift to the petitioner for their marriage, and that they
started living there after its turnover on 2 August 2018.

EXHIBIT 3 Certificate of Employment of the Respondent from

Anytime Fitness Center
EXHIBIT 3-A Signature of Jerome A. Cheng
EXHIBIT 4 Company Id of the Respondent at Anytime Fitness
Center
 PURPOSE: These documents are being offered to prove
respondent’s employment in Anytime Fitness Center.

EXHIBIT 5 Statement of Account of Respondent’s BPI Credit

Card
EXHIBIT 5-A Payment of MERALCO and Maynilad Bills by the
Respondent as Reflected on his August 2013
Statement
of Account from BPI Express Credit
EXHIBIT 5-B Payment of MERALCO and Maynilad Bills by the
Respondent as Reflected on his September 2013
Statement of Account from BPI Express Credit
EXHIBIT 5-C Payment of MERALCO and Maynilad Bills by the
Respondent as Reflected on his September 2018
Statement of Account from BPI Express Credit

PURPOSE: The document is being offered to prove that

respondent contributed to the family’s monthly utilities, and that he paid for the
monthly dues for the 1-bedroom condominium unit he bought at pre-selling as
gift to the petitioner for their marriage.

EXHIBIT 6 Certificate of Housing Loan Obtained by the

Respondent
with BPI Family Bank
EXHIBIT 6-A Amount of the Monthly Payment to be made by the
Respondent for the Housing Loan he Obtained from
the BPI Family Bank for the One-Bedroom
Condominium Unit he purchased at Pre-Selling

PURPOSES: The document is being offered to form part of

the testimony of the respondent, and to prove that he bought a condominium unit
as a gift to the petitioner for their marriage.

EXHIBIT 7 Diploma of Dr. Maria Lea Bernadeth S. Otico from

University of the Philippines-Visayas as a graduate of
the degree of Bachelor of Arts Major in Psychology
EXHIBIT 8 Diploma of Dr. Maria Lea Bernadeth S. Otico from De
La Salle University as a graduate of the degree of
Maters of Psychology Major in Clinical Psychology
EXHIBIT 9 Professional Identification Card of Dr. Maria Lea
Bernadeth S. Otico as a Licensed Psychometrician
EXHBIT 10 Abstracts of Articles Written by Dr. Maria Lea
Bernadeth
S. Otico
EXHIBIT 11 Psychological Examination Report Conducted by Dr.
 Maria Lea Bernadeth S. Otico on Petitioner and
Respondent
EXHIBIT 11-A Signature of Dr. Maria Lea Bernadeth S. Otico

PURPOSES: These are being offered as part of the testimony of Dr.

Maria Lea Bernadeth S. Otico, the psychologist who conducted the
psychological evaluation on the petitioner and the respondent. These are
likewise being offered to prove that after the study, it was found out that the
respondent is not psychologically incapacitated as the Petition alleges. Instead, it
was the petitioner herself who is psychologically incapacitated to comply with
the respective marital obligations of the spouses embodied in the Family Code,
as she is suffering from a Narcissistic Personality Disorder with Anti-Social
Traits. That said psychological incapacity on the part of the petitioner is grave,
incurable, and with juridical antecedence, and had existed before and during the
marriage.

EXHIBIT 12 Contract to Sell of the One-Bedroom Condominium

Unit
in Chateau Elysee located at Better Living
Subdivision,
Paranaque City, entered between SM Development
Corporation and Desiree Villas
EXHIBIT 12-A Signature of Desiree Villas

PURPOSE: These are being offered to prove that Desiree Villas

lived in Chateau Elysee located at Better Living, Paranaque City, and that she is
a neighbor of the petitioner and the respondent.

EXHIBIT 13 Contract of Accommodation Entered by the Petitioner

and One Alexandra Berdin Involoving a Condominium
Unit

PURPOSES: The document is being offered prove that the

Respondent has no knowledge of any accommodation entered by him in favor of
a third person involving a condominium unit, and that said unit is different from
the one-bedroom condominium unit he purchased at pre-selling at Chateau
Elysee as a gift to the petitioner for their marriage.

EXHIBIT 14 Screenshot of an Alleged Text Messages Between the

Respondent and Elijah Ong

PURPOSE: The document is being offered to prove that the

Respondent has no knowledge of any of the messages contained therein.

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.

Makati City, 7 December 2019.

(Sgd.) Atty. Angela Felipe

Counsel for Respondent
10I, PBCom Tower
Ayala Avenue Corner V.A. Rufino St.
Makati City
IBP No. 72315 dtd. 11-10-10 Makati
City
PTR No. 8029819 / 09/17/12 Makati
Roll No. 14562
MCLE Compliance II – 0008179
Dtd. January 25, 2019

(Sgd.) Atty. Laurisse Marie T.

Perianes
Counsel for Respondent
10I, PBCom Tower
Ayala Avenue Corner V.A. Rufino St.
Makati City
IBP No. 71095 dtd. 10-07-12 Makati
City
PTR No. 8029940 / 10/07/12 Makati
Roll No. 12345
MCLE Compliance II – 0007819
Dtd. January 27, 2019

(Sgd.) Atty. Joey Sulte

Counsel for Respondent
10I, PBCom Tower
Ayala Avenue Corner V.A. Rufino St.
Makati City
IBP No. 98712 dtd. 01-05-11 Matai City
PTR No. 6579810 / 01/05/11 Makati
Roll No. 02829
MCLE Compliance II – 0003912
Dtd. January 5, 2019