Republic of the Philippines

9th Judicial Region

MUNICIPAL TRIAL COURT IN CITIES
LAMITAN CITY
Province of Basilan

AILEEN AGUILAR SANSON CIVIL CASE NO. 564

Plaintiff,
-for-
-versus-
MORAL DAMAGES
MARIE LHEN P. SANSON under Art. 2219 in relation
Defendant. to Art. 26 (2) of the New
Civil Code
x----------------------------------------x

JUDICIAL AFFIDAVIT of PLAINTIFF

WITNESS: NAME - AILEEN AGUILAR SANSON

ADDRESS - Sitio Tinog, Barangay Ubit, Lamitan City, Basilan

OCCUPATION - Housewife

OFFER OF TESTIMONY: The testimony of the witness is being offered to prove

and corroborate the material allegations on the following relevant points:

1. that she accidentally discovered that Defendant, using the mobile phone
of Plaintiff’s son, chatted with Katherine;
2. that the discovery of the chat messages caused Plaintiff to distrust her
husband once again;
3. that she GRAVELY quarrelled with her husband after discovering the
conversations between Defendant and Katherine;
 4. that Plaintiff deeply suffered emotional distress and from sleepless nights
after the discovery;
5. the existence of the screenshots of the chat conversations between
Defendant and Katherine;
6. she will also identify the printed copy of the said screenshots in court and
will serve as the testimonial sponsor thereof; and
7. Such other matters as maybe relevant to the Plaintiff’s cause of action.

I, AILEEN AGUILAR SANSON, of legal age, married, Filipino Citizen and

with address at Sitio Tinog, Barangay Ubit, Lamitan City, Basilan, Philippines,
under oath, and with the assistance of my mother AILEEN AGUILAR SANSON,
do hereby depose and state that:

PRELIMINARY STATEMENT

ATTY. RAUDA I. SALISA, with office address at Seaside Barangay,

Isabela City, Basilan, conducted my examination as a plaintiff at her law office. I
am answering the questions asked of me fully conscious that I do so under oath
and may face criminal liability for false testimony and perjury.

QUESTIONS AND ANSWERS

Q1: What is the reason for your presence here today?

A1: I am here to execute my judicial affidavit as Plaintiff in an action which I am
instituting against the Defendant, MARIE LHEN P. SANSON.

Q2: Who is this Marie Lhen P. Sanson?

A2: She is the first cousin of my husband, Joseph N. Sanson. She is my cousin-
in-law.
Q3: What is your complaint against the Defendant?
A3: She disturbed the peace of our family. She caused me and my husband to
quarrel gravely.

Q4: When did this happen?

A4: Sometime in February, 2020.

Q5: How exactly did the Defendant disturb the peace of your family?
A5: She borrowed the mobile phone of my child, John Uriel and used the same to
chat with a girl named KATHERINE EVANGELISTA RUBIO.

Q6: Who is this Katherine Evangelista Rubio?

A6: Katherine was a woman because of whom I once SERIOUSLY quarrelled
with my husband Joseph. Katherine was a high school classmate of Joseph in
Claret College of Lamitan. She is now residing in Manila City. When Joseph went
to Manila to take his Marina Licensure Exam, Joseph admitted to me that he had
contact with Katherine through Facebook chat and text messages.

Q7: Did you resolve this quarrel with your husband?

A7: Yes. Joseph went home to Lamitan City, Basilan just to apologize for his
faults. After a few days, Joseph and I reconciled. For the sake of our children, I
forgot and forgave Joseph’s shortcomings. Moreover, Joseph swore and
promised he would not do any such activity ever again.

Q8: How did you learn that Defendant chatted with Katherine?
A8: Sometime in February 2020, I was checking the mobile phone of my son
John Uriel. I was shocked when there appeared a pop-up notification in the
Messenger app in John Uriel’s phone. The pop-up notification showed the face of
a woman whom I immediately recognized as Katherine, the woman who flirted
with my husband.

Q9: What did you do then?

A9: I was angered and baffled as to why my son received a message from
Katherine, I called John Uriel and asked him about the matter. John Uriel was
also surprised. However, when we checked the message, we found out that the
Facebook account logged in into John Uriel’s mobile phone was that of the
Defendant.

Q10: How came the Defendant’s Messenger account was logged into your son’s
mobile phone?
A10: My son recalled and told me that the Defendant borrowed his phone the
day before. He also said that the Defendant logged into her Messenger account
using my son’s phone.

Q11: What did you do then?

A11: When we tapped the notification button on the Messenger app, the
messages showed up right away. We were able to read the chat conversations
between the Defendant and Katherine.

Q12: What were the contents of the conversation between the Defendant and
Katherine?
A12: There were so many things that they discussed.

Q13: Can you tell us one of those things that they discussed?
A13: Yes. In one of the conversations, Katherine kept on asking Defendant for
information regarding my husband Joseph’s activities. Defendant told Katherine
about the cancelled flight of my husband. She also told Katherine about how my
husband and I met in Zamboanga City and spent a day and night therein.

Q14: What else did the Defendant and Katherine discuss in their chat?
A14: The conversation also showed that Katherine told Defendant to send her
new pictures of my husband to which Defendant agreed. At one point, Katherine
devised a way as to how Defendant may obtain a photo of my husband to which
Defendant likewise agreed.

Q15: Are there more things they discussed?

A15: Yes. Worst of all, in one conversation, Katherine told Defendant that she
invited my husband to once again meet in Manila. However, Katherine said that
my husband turned down the invitation. To this, Defendant TOLD KATHERINE
TO FORCE MY HUSBAND TO MEET UP AS THE LATTER IS SIMPLY ACTING
UP.

Q16: What measures did you take regarding the chat conversations?
A16: I took screenshots of the said conversations. I wanted to preserve them for
future use as evidence of the Defendant’s wrongdoings.

Q17: How did the discovery of the chat messages affect you?
A17: I suffered heavily from the discovery of those messages. As a wife, once
again I was hurt because I thought my marriage was in danger. I was most hurt
because I never imagined that a relative of my husband was trying to help a
stranger to get in touch with him. Such offense is aggravated by the fact that
Defendant used the mobile phone of my son to chat with Katherine.

Q18: Did you tell your husband Joseph of your discoveries?

A18: Yes. When I relayed my discoveries to Joseph, he was already on board
the vessel and was at work as a seaman. I confronted him through the phone.

Q19: What happened in your confrontation?

A19: We quarrelled over the phone. I yelled at Joseph over the phone. I
DISTRUSTED my husband once again. This time, our quarrel was graver.

Q20: How did your quarrel affect you?

A20: I suffered sleepless nights and severe anxiety due to the situation. I even
contemplated on filing an action for separation against my husband. However,
Joseph kept saying and swearing that he never did anything wrong again.

Q21: What happened after that?

A21: My worries increased the next few days because my husband Joseph
called his mother, Carmelita N. Sanson and told the latter that he would rather
die than have a broken family. Carmelita told me that Joseph had entertained
suicidal thoughts because of the quarrel and the embarrassment.
Q22: What else did Carmelita tell you?
A22: Carmelita begged me to calm down and listen to my husband’s
explanations. She implored me to be forgiving of Joseph as he is at work and any
emotional stress on him might prove dangerous.

Q23: What did you do after?

A23: I lodged my complaint with the Barangay Officials of Ubit, Lamitan City
against the Defendant. A settlement was not reached so I was issued by the
Barangay Chairman a Certification to File Action.

Q24: Are there anything more you want to say?

A24: Nothing more.

In witness whereof, I have hereunto set my hand this 16th day of October,
2020 in the City of Isabela, Philippines.

AILEEN AGUILAR SANSON

Affiant

Subscribed and sworn to before me this 16th day of October, 2020 in the
City of Isabela, Philippines.

Doc. No. ____;

Page No. ____;
Book No. ___;
Series of 2020

ATTESTATION

I, ATTY. RAUDA I. SALISA, of legal age, Filipino, single, and with office
address at Seaside Barangay, Isabela City, Philippines, do hereby depose and
state, that:
 1. I faithfully recorded or caused to be recorded the questions asked and
the corresponding answers that the witness gave in accordance with
Section 4 of A.M. No. 12-8-8-SC otherwise known as the Judicial
Affidavit Rule;

2. Neither I nor any other person then present or assisting with the above-
stated Judicial Affidavit coached the witness regarding the answers
given by the latter;

3. I am executing this Affidavit to attest to the authenticity, genuineness,

and veracity of the facts laid down in the above Judicial Affidavit of the
witness for whatever legal purpose it may serve within the boundaries
set forth by law.

IN WITNESS WHEREOF, I have hereunto affixed my signature this 16 th

day of October, 2020 in the City of Isabela, Philippines.

ATTY. RAUDA I. SALISA

IBP No. 06-9846-01-01/17/2019

Subscribed and sworn to before me this ___ day of _______, 2020 at the
City of Isabela, Philippines.