Xavier University – Ateneo de Cagayan

Practice Court I
S.Y. 2020-2021

Moot Court

People of the Philippines, Plaintiff

vs

Pedring Mangtas, Defendant

Participants in Trial:

Judge - Ali Munder

CLERK Of Court - Maxrio Simbajon
Stenographer
Plaintiff - COMPLAINANT Perlas Mangtas (Omos)
Plaintiff’s Lawyer - PROSECUTOR Gregorio Esteban (Elegio)
Defendant - ACCUSED Pedring Mangtas (Maagad)
Defendant’s Lawyer - DEFENSE Theodore Rodriguez (Roa)
Witness 1 –COMPLAINANT Perlas Mangtas
Witness 2 – EXPERT WITNESS 1 – Dr. Carlo Cruz Surgeon (Vitorillo)
Witness 3 - EXPERT WITNESS 2 – Dr. Bunch Psychiatrist (Ogatis)
Witness 4 – PARAMOUR - Hayley Williams (Ponferrada)

CLERK OF COURT: All rise the court is now on session, the Honorable Ali Munder
presiding. Silence is enjoined.

Let us all bow our head and pray the court’s ecumenical prayer:

“Almighty God, we stand in Your Holy Presence as Our Supreme Judge. We humbly
beseech You to bless and inspire us, so that what we think, say or do will be in
accordance with Your divine will. Enlighten our minds, strengthen our spirits, and fill our
hearts with fraternal love, wisdom, and understanding, so we become effective channels
of truth, justice, and peace, in our proceedings today, guide us to the path of
righteousness for the fulfillment of your greater glory. Amen.”

JUDGE: Call the first case.

CLERK OF COURT: Criminal Case No. R-CDO-008-2020 People of the Philippines

versus Mr. Pedring Mangtas (played by Lorenzo Maagad) for Vilation of Section 5(a) of
R.A. 9262 (Anti-Violence Against Women and their Children Act of 2004).

JUDGE: Today’s incident is for the arraignment of the accused and pre-trial. Any
appearances?
PROSECUTOR: Asst. City Prosecutor (ACP) Gregorio Esteban, appearing for the
prosecution, your honor.

DEFENSE COUNSEL: Atty. Theodore Rodriguez, appearing for the accused, Your
Honor.

JUDGE: Accused, Pedring Mangtas, please come forward (turn on your mic). Has your
counsel explained to you what will transpire at today’s arraignment?

CLERK OF COURT: Napasabut ba sa imong abogado unsay mahitabo sa pagpamati

karon?

ACCUSED: Opo.

JUDGE: Do you understand the English language, or do you wish to be arraigned in a

language other than English?

ACCUSED: I can understand the English language, Your Honor.

JUDGE: Let’s proceed with the arraignment and read the information to the accused.

CLERK OF COURT: (Calling the accused and advised the accused to stand properly
and listen and reads the whole information)

People of the Philippinesvs.Pedring Mangtas

Criminal Case No. R-CDO-008-2020Complaint For: Violation of Section 5(a); 5 (e) (1)
(2); and 5(i) of R.A. 9262(Anti-Violence Against Women and their Children Act of 2004),

INFORMATION:

The undersigned Assistant Prosecutor Gregorio Esteban accused Pedring Mangtas of

the crime of violation of Section 5(a); 5 (e) (1) (2); and 5(i) of R.A. 9262 (Anti-Violence
Against Women and their Children Act of 2004), which are committed as follows:

That on or about the evening of January 11, 2019 in Cagayan de Oro City, Philippines,
the above-named accused did then and there willfully, unlawfully and feloniously inflict
physical violence upon Perlas Mangtas a woman with whom he has three common
children, resulting to mental and emotional anguish and public ridicule or humiliation by
dragging the victim by hair from their residence’s gate to their house.

CONTRARY TO LAW, with the offense being attended by the special qualifying
aggravating circumstance of the victim being pregnant at the time.
CLERK OF COURT: Did you understand what was just read? What is your plea?
Guilty or not guilty?

ACCUSED: Not guilty.

CLERK OF COURT: Accused your honor, pleaded not guilty to the crime charged.

JUDGE: Let us proceed to pre-trial.

ORDER

When this case was called this morning, accused, assisted by counsel, was arraigned in
the Visayan dialect, the dialect which he spoke and fully understood, and when asked,
pleaded not guilty to the crime charged. Afterwhich pre-trial conducted, closed and
terminated.

Initial presentation of prosecution’s evidence set on April 12, 2019 at 8:30 a.m.

Subpoena ordered issue to the following people:

a. Dr. Carlo Cruz of Lapasan, Cagayan de Oro City
b. Dr. Farrah Agustin Bunch of Golden Glow, Pueblo de Oro Cagayan de Oro
c. Hayley Williams of PhilAm Life Village, Pueblo de Oro Cagayan de Oro City
for them to appear and testify on said date.

So ordered.

Judge

TRIAL PROPER
CLERK OF COURT: All rise. The court is now in session, the Honorable Ali Munder
presiding. Silence is enjoined.

Let us all bow our head and pray the court’s ecumenical prayer:

“Almighty God, we stand in Your Holy Presence as Our Supreme Judge. We humbly
beseech You to bless and inspire us, so that what we think, say or do will be in
accordance with Your divine will. Enlighten our minds, strengthen our spirits, and fill our
hearts with fraternal love, wisdom, and understanding, so we become effective channels
of truth, justice, and peace, in our proceedings today, guide us to the path of
righteousness for the fulfillment of your greater glory. Amen.”

CLERK OF COURT: Criminal Case No. R-CDO-008-2020 People of the Philippines

versus Mr. Pedring Mangtas for Violation of R.A. 9262 or the Anti-Violence against
Women and Children Act of 2004.

JUDGE: Appearances.

PROSECUTOR: Asst. City Prosecutor (ACP) Gregorio Esteban, appearing for the
prosecution, your honor.

DEFENSE: Atty. Theodore Rodriguez, appearing for the defense, your honor.

JUDGE: Today’s incident is for the presentation of the prosecution’s witnesses. Call on
your witness Prosecutor Esteban.

PROSECUTOR: I have three (3) witnesses for today your honor: the private
complainant, the medical doctor and psychiatrist, your honor.

JUDGE: Any comment from the defense?

DEFENSE: Your Honor, the defense would like to request that the other witnesses of
the prosecution be excluded from this room until such time that he/she is called to
testify.

JUDGE: Granted. Prosecution’s witnesses are excluded until such time that the witness
is called to testify. Prosecution, please proceed with your first witness.

PROSECUTOR: Your Honor, the prosecution is calling to the witness stand, the private
complainant, Mrs. Perlas Batungbakal-Mangtas.

COURT INTERPRETER: Perlas Batungbakal-Mangtas, please take the witness stand.

Please raise your right hand. Do you swear to tell the truth, and nothing but the whole
truth in today’s proceedings?

COMPLAINANT: I do.
CLERK OF COURT: Please state your name, age, civil status, occupation, residence,
highest educational attainment.

COMPLAINANT: Perlas Batungbakal, 38 years of age, married, paralegal, presently

residing at Barangay Carmen, Cagayan de Oro City, and a college graduate.

CLERK OF COURT: For the record your honor, the witness is Perlas Batungbakal, 38
years of age, married, paralegal, presently residing at Barangay Carmen, Cagayan de
Oro City, and a college graduate.

JUDGE: Your witness Prosecutor Esteban.

PROSECUTION - COMPLAINANT DIRECT EXAMINATION

PROSECUTOR: May it please the honorable court.

JUDGE: Proceed.

PROSECUTOR : Your Honor, the prosecution is offering the testimony of our first
witness, the private complainant herself, Mrs. Perlas Batungbakal-Mangtas, to prove the
(1) material allegations in the Complaint; (2) to identify the defendant in this case; (3) to
identify pertinent documents; and (4) to testify on such other matters as may be
relevant, your Honor. With the permission of the Honorable Court, the prosecution
would like to proceed, your Honor.

JUDGE: Proceed.

PROSECUTOR: Mrs. Mangtas, do you personally know the accused in this case?

COMPLAINANT: Yes, Atty.

PROSECUTOR: Is the accused present in the courtroom today? If yes, please identify
the accused by pointing and describing him.

COMPLAINANT: Yes, Atty. He is there wearing an orange shirt with a big letter “P”
printed on it.

CLERK OF COURT: The court would like to request the accused to stand and
introduce yourself.

ACCUSED: My name is Pedring Mangtas, (age, address, occupation)

CLERK OF COURT: For the record your Honor, the accused who is present today is
Mr. Pedring Mangtas, (age, address, occupation)
JUDGE: Fiscal, please continue.

PROSECUTOR: Thank you, Your Honor. Moving on. Mrs. Mangtas, how are you
related to the accused?

COMPLAINANT: He is my husband, Atty.

PROSECUTOR: Do you have a copy of your marriage certificate to prove that he is,
indeed, your husband?

COMPLAINANT: Yes, Atty.

PROSECUTOR: Mrs. Mangtas, I am showing you this document. Please take a look.
(Pros to read the pertinent details) How is this related to the marriage certificate that you
just said you have.

COMPLAINANT: This is exactly the document that I have, Atty. This is our marriage
certificate.

PROSECUTOR: Can you please tell the court who are the parties in this certificate?

COMPLAINANT: Pedring Mangtas, who is my husband and myself, his wife.

PROSECUTOR: Thank you. Now, there are signatures in this marriage certificate, can
you recognize whose signatures are these?

COMPLAINANT: Yes, Atty. The signature above my name is my signature, and the one
above the name Pedring Mangtas is my husband’s signature.

PROSECUTOR: Your Honor, may I request that this marriage certificate be marked as
Exhibit A and the signatures of Perlas Mangtas and Pedring Mangtas as Exhibits A-1
and A-2 respectively, to prove that the parties herein are legally married.

JUDGE: Granted. Mark it.

PROSECUTOR: Mrs. Mangtas, how long have you been married with the accused?

COMPLAINANT: 5 years, Atty.

PROSECUTOR: How many kids do you have with the accused, if any?

COMPLAINANT: Three (3) kids.

PROSECUTOR: Can you describe to this court your relationship with the accused
during the five long years?
COMPLAINANT: The first few years of our married life was okay. We used to be happy.
Later on, however, it turned sour when he started being too dominant and controlling.

PROSECUTOR: What do you mean by being too dominant and controlling, Mrs.
Mangtas. Please clarify your answers.

COMPLAINANT: He always demanded absolute obedience from me and our children.

When I took up law, and even when I was already working part time at a law office, he
trivialized my ambitions. He keeps on telling me that I should stop studying and working,
and that I should stay at home instead.

PROSECUTOR: And every time he tells you these things - to stop from studying and
from working and just stay at home - what is your usual response?

COMPLAINANT: I usually tell him that I really want to become a lawyer and that I am
working to finance my schooling so that our budget for our family’s sustenance will be
used mainly for its purpose. But he still cannot understand. That is why he always ends
up forcing me not to attend my classes and be absent from my work.

PROSECUTOR: In your affidavit, Mrs. Mangtas, you mentioned several instances that
your husband is hurting you physically. Can you still recall when these physical abuses
started?

COMPLAINANT: Yes, Atty.

PROSECUTOR: Please tell the court when the accused started causing physical harm
to you?

COMPLAINANT: It was on the third year of our marriage when I discovered that he was
having an affair with Ms. Hayley Williams, who is also the godmother of one of our sons.

PROSECUTOR: By “having an affair, what do you mean by this, Mrs. Mangtas?

COMPLAINANT: They have a romantic relationship, Atty.

PROSECUTOR: How did you know about this romantic relationship?

COMPLAINANT: One night, I heard him saying “I love you” while talking to someone
over the phone. I confronted him about it. In the course of our argument, he later on
confessed that he was, indeed, having an affair with Hayley.

PROSECUTOR: After he confessed to you that he is having a romantic relationship with

Ms. Hayley Williams, what did you do, if any?
COMPLAINANT: I just started crying out loud in pain but Pedring told me that I was
over-dramatic. He told me to stop crying but of course I cannot stop from crying that
night because it’s very painful to know that he is cheating on me.

PROSECUTOR: While you were crying, what did the accused do?

COMPLAINANT: He grabbed me by my hair and pushed me hard, which caused me to

fracture my right foot.

PROSECUTOR: When did this happen?

COMPLAINANT: Around November of 2018.

PROSECUTOR: What is your proof that you, indeed, suffered a fracture in your right
foot?

COMPLAINANT: I have a copy of my x-ray result, Atty.

PROSECUTOR: Mrs. Mangtas, I am showing you a copy of an x-ray result. Please take
a look. It shows that there is a fracture in the right foot of the patient. How is this related
to the x-ray result that you mentioned earlier?

COMPLAINANT: This is my x-ray result, Atty.

PROSECUTOR: Your Honor, the prosecution would like to request that this copy of the
x-ray result be marked as Exhibit-B to prove that the complainant, indeed, suffered a
fracture in her right foot.

JUDGE: Granted. Mark it.

PROSECUTOR: Thank you, your Honor. Moving on. Mrs. Mangtas, is the accused
informed that you suffered that fracture?

COMPLAINANT: Yes, Atty.

PROSECUTOR: After he knew of that fact, what did the accused do? Did he ask for an
apology?

COMPLAINANT: No, Atty. No signs of remorse from him.

PROSECUTOR: I see. If he did not ask for an apology? What did the accused do, if
any?

COMPLAINANT: He, again, physically abused me, Atty.

PROSECUTOR: When did this happen?

COMPLAINANT: I cannot remember the exact dates of the other several instances,
Atty. But I am sure that one happened last January 11, 2019, during our anniversary.

PROSECUTOR: How did he “physically” hurt you during that date?

COMPLAINANT: He arrived late that night. I asked him why he was late and why he
forgot that it was our anniversary, but he ignored me. I grabbed his arm to get his
attention, but he suddenly slapped me causing my lips to bleed.

PROSECUTOR: What did you do next, if any?

COMPLAINANT: I shouted at him and told him that I will leave him and that I will bring
the kids with me.

PROSECUTOR: What was his response, if any?

COMPLAINANT: He turned around and grabbed my arm forcefully and pushed me unto
the wall. He threatened me that if we will leave, he will not give support and that there’s
no way that we could live on our own since we are dependent on him, and that it is only
through him that we can have a better life.

PROSECUTOR: What did you do after that, if any?

COMPLAINANT: I tried to let go of his hold, because I was so scared. I ran towards the
gate to ask for help but he immediately grabbed me by the hair. My right hand was
holding the bar in our gate trying to stop him from dragging me back towards the house
but my attempt was futile. He dragged me inside the house by my hair. I was down on
the ground begging for him to stop, but he remained so rude.

PROSECUTOR: What happened next after that, if any?

COMPLAINANT: When we were already inside the house, he pinned me down and
started choking me. I begged him to stop it because I couldn’t breathe. I was crying until
the kids run towards me and they hugged me. Only then that he stopped hurting me.
The kids saw the bruises and scrapes in my elbows and knees. They started crying as
well.

(Pwede diri isingit tong photos ni Kim)

PROSECUTOR: Did you have the chance to report this incident to your siblings or
parents?

COMPLAINANT: No, Atty.

PROSECUTOR: How about with a police officer?

COMPLAINANT: Yes, Atty. I reported it to the nearest police station to have a record of
that incident.
PROSECUTOR: Mrs. Mangtas, I am showing you a copy of a Certification of Police
Blotter Entry No. 873641-3834-231 dated January 12, 2019 Carmen Police Station No.
4. Do you recognize this document?

COMPLAINANT: Yes, that is the police blotter that I am referring, Atty.

PROSECUTOR: May I request your Honor to have this certification of the police blotter
be marked as Exhibit C to prove that the incident was, indeed, reported to the police on
January 12, 2019.

JUDGE: Mark it.

PROSECUTOR:

PROSECUTOR: Thank you, your Honor. After reporting the incident to the police, what
did you do next?

COMPLAINANT: I went to the hospital and had my injuries checked.

PROSECUTOR: Do you have a proof that you, indeed, went to a hospital?

COMPLAINANT: Yes, Atty. I secured a copy of a Medical Certificate.

PROSECUTOR: Mrs. Mangtas, I am showing you a copy of a Medical Certificate from

(Name of Clinic/Hospital and Attending Physician). Please take a look. How is this
related to the Medical Certificate that you mention just now?

COMPLAINANT: That is the Medical Certificate issued to me, Atty.

PROSECUTOR: May I request your Honor to have this Medical Certificate be marked
as Exhibit D to prove that the Complainant, indeed, consulted a physician after the
incident.

JUDGE: Mark it.

PROSECUTOR: No further questions, your Honor.

JUDGE: Any cross?

DEFENSE: Yes, your honor.

DEFENSE - COMPLAINANT CROSS EXAMINATION OF THE FIRST WITNESS

DEFENSE: Earlier, you mentioned that in the first few years of your marriage, you and
the accused are living happily, is that correct?

COMPLAINANT: Yes, that is correct.

DEFENSE: And this was before you started going to law school and worked part time at
a law office as a paralegal, is that correct?

COMPLAINANT: Yes.

DEFENSE: Mrs. Mangtas, what time do you usually leave the house to work and attend
classes?

COMPLAINANT: Around 7:30 in the morning.

DEFENSE: And what time do you arrive at home?

COMPLAINANT: Around 10:00 in the evening.

DEFENSE: Does this happen every day?

COMPLAINANT: Yes, except on Sundays.

DEFENSE: What about your husband? What time does he leave and arrive at home?

COMPLAINANT: We leave the house at the same time. But I am not sure what time he
goes home. I only know that he finishes his work at 5:00 in the afternoon.

DEFENSE: Who, then, looks after the children when both you and your husband are not
home?

COMPLAINANT: My mother who is living with us.

DEFENSE: So, your husband and your kids have to wait for you until 10 in the evening,
is that correct?

COMPLAINANT: Yes, that is correct.

DEFENSE: Upon arriving at home, do you usually talk with your husband how your day
went or do you sleep right away, or any?

COMPLAINANT: I – I sleep right away because I am so tired.

DEFENSE: Mrs. Mangtas, did you lose affection for your husband because you got
busy and has no time for him or at least attend to his needs as a wife?

PROSECUTION: Objection, your Honor. Speculating.

JUDGE: Objection overruled.

DEFENSE: You mentioned earlier that the accused told you to stop studying and just
stay at home, is that correct?

COMPLAINANT: Yes, that is correct.

DEFENSE: Is the accused earning enough money to support you and the children?

COMPLAINANT: Yes. He does, more than enough actually. But I want to help him and
also because I get bored at home, so I decided to enter law school.

DEFENSE: But, as a wife, looking after your children and attending to the needs of your
husband is considered help already, is it not?

COMPLAINANT: Yes, it is.

DEFENSE: In the early years of your marriage, did your husband ever hit you?

COMPLAINANT: No, sir.

DEFENSE: You said, the accused grabbed you by your hair and pushed you hard,
correct?

COMPLAINANT: Yes.

DEFENSE: I am presenting to you this photo; can you identify who is in the picture?
(Witness examines the photo)

COMPLAINANT: That is my husband.

DEFENSE: What is on his back?

COMPLAINANT: A scar.

DEFENSE: Can you tell me what caused this scar?

COMPLAINANT: I caused the scar unintentionally.

DEFENSE: May I request Your Honor to have this photo marked as Exhibit 1 to show
the wife’s tendency to inflict physical harm to the accused.
JUDGE: Mark it.

DEFENSE: Can you tell us what happened with regards to that scar?

COMPLAINANT: One evening, he came home late at night so I asked him where he
was from, yet he turned his back on me.

DEFENSE: When he turned his back on you, what did you do?

COMPLAINANT: I tried to get a hold of him but somehow my fingers slipped across his
back, leaving that scar.

DEFENSE: You said that you were hospitalized for the wounds and injuries caused by
the accused?

COMPLAINANT: Yes, sir.

DEFENSE: Do you have a skin condition that get you easily bruised if you get hit by a
hard object?

COMPLAINANT: Yes.

DEFENSE: How did you acquire it?

COMPLAINANT: It runs in our family.

DEFENSE: Did you ever try to harm yourself?

COMPLAINANT: No.

DEFENSE: According to your affidavit Mrs. Mangtas, you tried to kill yourself and I
quote “I wanted to end it all”? Is this true?

COMPLAINANT: Yes, but it was because I could no longer tolerate the abuses of my
husband!

DEFENSE: No further questions, your Honor.

JUDGE: Any redirect?

PROSECUTOR: Yes, your honor.

PROSECUTION - COMPLAINANT RE-DIRECT EXAMINATION

PROSECUTOR: Mrs. Mangtas, you are working as a PART-TIME paralegal. Is that
correct?

COMPLAINANT: Yes, Atty. That is correct.

PROSECUTOR: Between what time are you expected to be in the office as a part-time
paralegal?

COMPLAINANT: From 11:00am to 12:30pm, Atty. Then, lunchbreak from 12:30pm to

1:30pm. My work resumes again from 1:30pm to 4:00pm.

PROSECUTOR: In terms of travel time, how far is your office from your house?

COMPLAINANT: Around 30 minutes travel via jeep, Atty.

PROSECUTOR: How come that you leave your house at 7:30am when in fact your
work starts at 11:00am and travel time is only 30 minutes?

COMPLAINANT: I go to work early because only in the office library that I can study.

PROSECUTOR: Why not in your house?

COMPLAINANT: I am afraid to study in the house Atty.

PROSECUTOR: Why are you afraid?

COMPLAINANT: Pedring will nag at me if he sees me studying at home.

PROSECUTOR: Why would he nag at you?

COMPLAINANT: I don’t know. He would say that I am robbing him and our kids an
opportunity of having quality family time.

PROSECUTOR: Is that true?

COMPLAINANT: No, Atty. I give quality time for them even if I am busy with work and
school.

PROSECUTOR: I see. But Mrs. Mangtas, earlier, you said that you immediately go to
sleep after having a very tiresome day at work and in school. This usually happens from
Mondays to Saturdays. How about your Sundays? How do you spend your Sunday?

COMPLAINANT: I always treat my Sunday as a family day, Atty. I spend the entire day
playing with the kids, watching movie with them and Pedring, and cooking their favorite
meals and snacks. It’s our bonding time as a family.
PROSECUTOR: So, are you saying that after all the heavy workloads in school and at
work, you still give quality time with your family?

DEFENSE: Objection, your honor. Leading.

JUDGE: Objection, overruled. (or sustained? What say you judge?) Please answer Mrs.
Witness.

COMPLAINANT: Yes, Atty.

PROSECUTOR: Going back to the skin condition that you mentioned earlier, is that
medically diagnosed?

COMPLAINANT: No, it's just a common skin condition that we have in the family. I
mean with my siblings.

PROSECUTOR: No further questions.

JUDGE: Any recross?

Defense: No re-cross your Honor.

ADMISSION OF EXPERT WITNESS

JUDGE: Alright. The first witness is now excused. Prosecutor, please call your next
witness.

PROSECUTOR: Your Honor, the prosecution is calling to the witness stand, Dr. Celine
Cruz, the attending physician, your honor.

COURT INTERPRETER: Dr. Cruz, will you please raise your right hand?

EXPERT WITNESS 1: Yes, Sir.

COURT INTERPRETER: Do you swear to tell the truth, the whole truth and nothing but
the truth?

EXPERT WITNESS 1: I do.

COURT INTERPRETER: Please take a seat.

EXPERT WITNESS 1: Thank you.

JUDGE: Dr. Cruz, you will be asked by the Prosecutor.

EXPERT WITNESS 1: Yes, your honor.

JUDGE: Alright, Prosecutor, whenever you’re ready.

PROSECUTOR: Thank you, your honor. Your Honor, we are offering the testimony of
this witness to prove the relevance of the medical certificate issued by the attending
physician of the private complainant. With the permission of the Honorable Court, may
we proceed your Honor.

JUDGE: Proceed.

PROSECUTOR: Dr. Cruz, please state your full name, age, occupation and other
personal circumstances

EXPERT WITNESS 1: I am Celine Cruz, 45 years of age, married, with residence at

Barangay Lapasan, Cagayan de Oro City. I am a licensed physician. I earned my
medical degree from Xavier University - Jose P. Rizal School of Medicine last 2008; I
had my post-graduate internship at the Philippine General Hospital; and I had my
residency for general surgery at Northern Mindanao Medical Center.

PROSECUTOR: What, if any, are your board certifications?

EXPERT WITNESS 1: I am a fellow of the Philippine Society of General Surgeons, the

Philippine College of Surgeons, and the Philippine Association of Laparoscopic and
Endoscopic Surgeons.

PROSECUTOR: How long have you been practicing as a physician, Dr. Cruz?

EXPERT WITNESS 1: I have been in the practice as a physician for 10 years.

PROSECUTOR: Your honor, this is to manifest that Dr. Cruz is an expert witness being
a licensed physician and having been in the practice of the same profession for 10
years.

JUDGE: Defense counsel, do you have any questions or objections to the witness’
credentials as an expert witness?

DEFENSE: None, Your Honor.

JUDGE: I recognized based on her documentary records that Dr. Cruz is qualified to be
an expert witness. Dr Cruz is admitted as an expert witness. Prosecutor, you may now
proceed with the direct examination.

PROSECUTOR: Thank you your honor.

 PROSECUTION – EXPERT WITNESS (ATTENDING PHYSICIAN)

DIRECT EXAMINATION

PROSECUTOR: Dr. Cruz, the reason why you are here today is because your name is
written in the medical certificate of the private complainant, Mrs. Perlas Batungbakal-
Mangtas. Are you aware of that?

EXPERT WITNESS 1: Yes, Sir.

PROSECUTOR: I am showing to you a copy of a medical certificate. Please take a

look. A signature is written there above your name. Can you recognize whose signature
is that?

EXPERT WITNESS 1: That is my signature, Sir.

PROSECUTOR: When did you issue this medical certificate?

EXPERT WITNESS 1: On January 12, 2019.

PROSECUTOR: To whom did you issue this medical certificate?

EXPERT WITNESS 1: To Perlas Batungbakal Mangtas.

PROSECUTOR: May I request your honor to have the signature of Dr. Celine Cruz on
this medical certificate dated January 12, 2019 be marked as Exhibit D-1.

PROSECUTOR: If that is your signature, how will you testify to the truthfulness of the
private complainant’s claim that she, indeed, went to your hospital, that you were the
attending physician that time, and that you issued her this medical certificate?

EXPERT WITNESS 1: Those are all true, Sir. I was the attending physician when she
arrived at the emergency room complaining about her injuries. I am the one who issued
that medical certificate to her after the medical examination that I conducted to her.

PROSECUTOR: What did you do when she arrived at the emergency room complaining
about her injuries, if any?

EXPERT WITNESS 1: I asked the nurses to get her personal details and vital signs.
After which, I conducted the physical examination.
PROSECUTOR: What were your medical findings after conducting the physical
examination?

EXPERT WITNESS 1: There was a noted swelling and deformity on the patient’s right
ankle with limitation of movement. I have also observed that the patient has contusion.
There was a violaceous discoloration on the patient’s arms measuring 4 cm x 4 cm,
tender upon palpation probably obtained by a blunt forceful trauma.

PROSECUTOR: Dr. Cruz, you have mentioned that there was a contusion. In layman’s
term, can you explain to this court what do you mean by contusion?

EXPERT WITNESS 1: Contusion means bun-og.

PROSECUTOR: What usually causes contusion?

EXPERT WITNESS 1: The contusion was probably caused by a fall, trauma, blow or
impact to the patient's body.

PROSECUTOR: Other than the contusion, what are your other observations or findings,
if any?

EXPERT WITNESS 1: There were also superficial skin abrasions over both her elbow
and knee.

PROSECUTOR: What do you mean by skin abrasions, Doc?

EXPERT WITNESS 1: An abrasion is a kind of open wound characterized by the

removal of the superficial epithelial layer of the skin caused by rub or friction against a
hard-tough surface. Sa Bisaya pa, pangos.

PROSECUTOR: Upon examination, how old were the skin abrasions on her elbows and
knees?

EXPERT WITNESS 1: Upon my examination, about less than a day. They were fresh
wounds.

PROSECUTOR: What could have caused those wounds?

EXPERT WITNESS 1: The pattern of the abrasion is suggestive that the victim was
dragged on a rough surface like a pavement.

PROSECUTOR: No further questions, your honor.

DEFENSE - EXPERT WITNESS (ATTENDING PHYSICIAN)

 CROSS EXAMINATION

JUDGE: Your witness, counsel, for cross examination.

DEFENSE: With the kind permission of the Honorable Court.

JUDGE: Proceed.

DEFENSE: Are all of your opinions stated with a reasonable degree of medical
certainty?

EXPERT WITNESS: Yes.

DEFENSE: Doctor, you have mentioned in your findings that Perlas Batungbakal-
Mangtas had a deformed ankle, could this have been caused by sprain from laborious
activities?

EXPERT WITNESS: Yes, it is a possibility.

DEFENSE: Upon your examination, you also found contusion on the Complainant, is
that right?

EXPERT WITNESS: Yes.

DEFENSE: You have also stated that the contusion was probably caused by a fall,
trauma, blow or impact to the patient's body. Is it possible that a patient could have
gotten contusion through her own individual act?

EXPERT WITNESS: Yes.

DEFENSE: Doctor, you also found that Perlas had superficial skin abrasions, correct?

EXPERT WITNESS: Yes, on both her elbows and knees.

DEFENSE: You also testified that the act of dragging a person on the ground is a
possible cause of an abrasion, correct?

EXPERT WITNESS: Yes.

DEFENSE: However, you have mentioned that abrasions are caused by rubbing or
friction against a hard-tough surface. Thus, there are other possible ways that cause an
abrasion, is that right?

EXPERT WITNESS: Yes.

DEFENSE: That would be all, your honor.

JUDGE: Would the Prosecution like to redirect?

PROSECUTOR: No, your honor.

DEFENDANT FIRST WITNESS – DIRECT EXAMINATION

JUDGE: Defense, are you ready to present your first witness,

DEFENSE: Yes, your honor. The defense is calling to the witness stand, Ms. Hayley
Williams, to refute the allegations of the prosecution that the accused intentionally
caused physical harm against the private complainant as well as the allegations on
extra-marital affairs of the defendant with Ms. Williams.

COURT INTERPRETER: Ms. Williams, please raise your right hand? Do you swear to
tell the truth, the whole truth and nothing but the truth?

PARAMOUR: I do.

DEFENSE: Please state your name, age, and other personal circumstances.

PARAMOUR: Haley Williams, 29 years of age, single, working as a bank manager for
Unibank, and presently residing at Philam Life Village, Pueblo de Oro, Cagayan de Oro
City.

DEFENSE: Do you know a person named Mr. Pedring Mangtas?

PARAMOUR: Yes.

DEFENSE: Is this person present here today? If yes, please point him.

PARAMOUR: Yes. * point finger at defendant*

(Ipatindog pa ba and identify himself?)

DEFENSE: How did you meet Mr. Pedring?

PARAMOUR: I met Pedring when he opened an account with our bank,

DEFENSE: Was that the only time you met him?

PARAMOUR: No. Mr. Pedring would visit the bank on Mondays and Thursdays for his
bank transactions.
DEFENSE: Can you describe to us your engagement with Mr. Pedring every time he
visits your bank?

PARAMOUR: He was very professional, and he was a valued client of ours.

DEFENSE: Does Mr. Pedring go alone everytime he visits to your bank?

PARAMOUR: No, Mr. Pedring sometimes brings her wife with him when visiting the
bank.

DEFENSE: Were your interactions strictly during bank visits?

PARAMOUR: No, at times Mr. Pedring would text me at night to inform that he will go
the bank the next day and ask priority for a faster transaction.

DEFENSE: Aside from work related communication, do you and Mr. Pedring talk about
other matters?

PARAMOUR: Yes, Mr. Pedring and his wife asked me to be the godmother of their son,
to which I accepted.

DEFENSE: Is that all?

PARAMOUR: I would at times check-up on Mr. Pedring on how he is and about my

godson, to which he would just reply to me that everything is well and okay.

DEFENSE: Since then, were your engagements the same?

PARAMOUR: No.

DEFENSE: What made say so?

PARAMOUR: His visits in the bank became unannounced and he no longer brings his
wife with him.

DEFENSE: Was this the only thing that you noticed?

PARAMOUR: No.

DEFENSE: What do you mean?

PARAMOUR: One evening, Mr. Pedring texted me and told me he was drunk, and
started sharing his personal issues about his wife, at first, I replied, but when the topic
was becoming too personal, I decided to cut the conversation.

DEFENSE: What particular personal issues did Mr. Pedring tell you about his wife?

PARAMOUR: Mr. Pedring said that his wife was an extreme nagger to the point that
Pedring would lose his temper, which would result with them fighting.
DEFENSE: Do you see Mr. Pedring as a person capable of hurting his wife?

PARAMOUR: No, Mr. Pedring seems to be a gentleman based on how he treats me

and my co-workers in the bank. He is very polite and patient to me and my subordinates
even when they would commit errors in the transactions.

DEFENSE: Did you and Mr. Pedring meet last November 2018?

PARAMOUR: Yes, we saw each other at a colleague’s house, celebrating her birthday.

DEFENSE: Why was Mr. Pedring present during this occasion?

PARAMOUR: Mr. Pedring attended the party because he was also invited by my
colleague.

DEFENSE: Did you happen to interact with Mr. Pedring at the party?

PARAMOUR: Yes, we had a small talk, but I avoided him afterwards because he was
already drunk.

DEFENSE: what time did you go home, and who was with you?

PARAMOUR: I stayed at the party until 1am, and went home alone thereafter.

DEFENSE: Where was Mr. Pedring at that time?

PARAMOUR: I did not see him anymore at that time at the party. I assumed he went
home earlier than me.

DEFENSE: So there is no intimate relationship happening between you and Mr.

Pedring, is that correct?

PARAMOUR: Yes.

DEFENSE: No further questions Your Honor.

DEFENDANT FIRST WITNESS CROSS EXAMINATION

CROSS EXAMINATION: PARAMOUR

JUDGE: The prosecution would like to cross?

PROSECUTOR: Yes, Your Honor. May I proceed?

JUDGE: Proceed.
PROSECUTOR: Thank you, Your Honor. Ms. Witness, how many clients do you handle
on a daily basis?

PARAMOUR: Too many to mention, Sir.

PROSECUTOR: Do your clients text you asking priority before their supposed
transaction?

PARAMOUR: Not all, Sir.

PROSECUTOR: By not all, do you mean there are some? If yes, how many of them?

PARAMOUR: Yes, Sir. Only 3 people who usually ask me for priority in their
transaction.

PROSECUTOR: Is Mr. Pedring one of those?

PARAMOUR: Yes, Sir.

PROSECUTOR: You said your communication is not limited to bank transactions, is

that right?

PARAMOUR: Yes, Sir.

PROSECUTOR: How often does Mr. Pedring messages you?

PARAMOUR: Every night after his bank transactions and during weekends, Sir.

PROSECUTOR: Do your other clients text you beyond bank transactions?

PARAMOUR: No, Sir.

PROSECUTOR: Thank you. No further questions, Your Honor.

FORMAL OFFER OF EVIDENCE - PROSECUTION

PROSECUTOR: Your Honor, please, after the testimony of our three (3) witnesses
namely, Perlas Batongbacal-Mangtas, Attending Physician Celine Cruz, and
Psychiatrist Farrah Agustin Bunch, the Prosecution has no more witnesses to present,
and no more documentary evidence to be marked.

We are now ready to present our formal offer of exhibits orally.

JUDGE: Proceed.
PROSECUTOR: Exhibit A and submarkings is formally offered to establish that Perlas
Batongbacal-Mangtas, herein private complainant and Pedring Mangtas, herein
accused, are married.

Exhibit B is formally offered to show that the private complainant sustained an injury due
to the battering incident in November 2018.

Exhibit C is formally offered to show that the private complainant likewise sustained
injuries due to the battering incident in January 11, 2019.

Exhibit D is formally offered to prove that the private complainant reported the battering
incident on January 11, 2019 to the police.

Exhibit E and sub-marking is formally offered to prove that based on the medical
findings of the attending physician, herein private complainant has sustained injuries.

Exhibit F and sub-marking is formally offered to prove that the private complainant is
diagnosed by the psychiatrist with Post Traumatic Stress Disorder comorbid with Major
Depressive Disorder.

JUDGE: Any comment from the defense?

(ENUMERATE ALSO ALL EXHIBITS OBJECTED, USUALLY BEING SELF-SERVING,

IRRELEVANT, MACHINE COPY, ETC.)

RULING ON THE OFFER

JUDGE: ORDER

When this case was called this morning, prosecution presented its three (3) witnesses,
namely Perlas Batongbacal-Mangtas, Dr. Celine Cruz, and Dr. Farrah Agustin Bunch
and have the following exhibits marked:

1. Exhibit A, the marriage certificate of Perlas Batongbacal-Mangtas and Pedring

Mangtas. Exhibits A-1 and A-2, respectively for the signatures of the parties in
the marriage certificate;
2. Exhibit B, a photograph showing a sprained right foot;
3. Exhibit C, a photograph showing skin abrasions on the elbow and knee;
4. Exhibit D, the Police Incident Report dated January 12, 2019;
 5. Exhibit E, the medical certificate dated January 12, 2019. Exhibit E-1for the
signature of the attending physician, Celine Cruz; and
6. Exhibit F, the medical certificate dated April 15, 2019. Exhibit F-1 for the
signature of the psychiatrist, Farrah Agustin Bunch.

There being no more witnesses to present and no more additional documents to be

marked, Prosecution proceeded to orally offer formal offer of exhibits. Over and above
the objection of the defense, all exhibits admitted for the purposes they were offered
and for which they were testified upon.

PROSECUTOR: After admission of our exhibits, Prosecution rests its case your Honor.