Republic of the Philippines

FAMILY COURT
Fourth Judicial Region
Branch 15
Lucena City, Quezon

ZENDRO ISMAEL BALON

IBARROLA,
Petitioner.

CIVIL CASE NO. 2020-34

- versus - For: “Declaration of Nullity
of Marriage”

RICHELL MAY COSEJO

IBARROLA,
Respondent.
x-----------------------------------------x

WRITTEN FORMAL OFFER OF EVIDENCE

Petitioner ZENDRO ISMAEL B. IBARROLA, unto this

Honorable Court, most respectfully submits its Formal Offer of
Evidence in support of his Petition:

Exhibit Description Purpose

A The Petition To prove the facts and

allegations in the
contents thereof in
support of the instant
Petition for Nullity of
Marriage and to
establish jurisdictional
requirements.

B Certificate of Residency To establish

issued by the Barangay compliance with
Chairperson of Barangay Supreme Court A.M.
6, Lucban, Quezon No. 02-11-10-SC, and
the jurisdictional
requirements in this
case, as well as to
show that the
Petitioner is a resident
of Lucban, Quezon;

1
C Sworn Statement of
Residency of Petitioner To establish
with House Location compliance with
Sketch Supreme Court A.M.
No. 02-11-10-SC, and
D Sworn Statement of the jurisdictional
Counsel Stating he has requirements in this
personally verified the case, as well as to
Petitioner’s Residency show that the
Petitioner is a resident
E Machine Copy of Unified of Lucban, Quezon;
Multi-Purpose ID of
Petitioner bearing the
photograph and address
of Petitioner

F Machine copy of the

Petitioner’s Driver’s
License

G Notice of Appearance of To prove that the

the Solicitor General Solicitor General
appeared on behalf of
the State in this case.

G-1 Deputization Letter To prove that the

Honorable Prosecutor
was deputized and
appointed to represent
the State in this case.

H Collusion Report To prove that there is

no collusion in this
case between the
Petitioner and
Respondent

2
I Judicial Affidavit of To prove that he
Petitioner ZENDRO initiated the instant
ISMAEL B. IBARROLA Petition for Nullity of
Marriage and to
establish the facts and
allegations therein,
such as the fact that
the Respondent
started a life with
another man and has
abandoned the
Respondent and her
children. Further, the
same is offered for the
purposes stated in his
judicial affidavit and
to serve as his direct
testimony in this case.

J Marriage Contract of To prove that the

ZENDRO ISMAEL B. witness affirms and
IBARROLA and Richell confirms the contents
May Cosejo Ibarrola of his Judicial
Affidavit

K Photograph on page 54 To prove that the

of the case record
L Photographs
Respondent is now in
a relationship with
another man, Rommel
Mazo, and has a child
with him, effectively
abandoning the
Petitioner and their
children

M Birth Certificate of To prove the birth of

Zendrich C. Ibarrola the first child of the
Petitioner and
Respondent

N Birth Certificate of To prove the birth of

Zhandrea C. Ibarrola the second child of
Petitioner and
Respondent

3
O Birth Certificate of Zian To prove the birth of
C. Ibarrola the third child of
Petitioner and
Respondent

P Birth Certificate of To prove the birth of

Zhabrinah C. Ibarrola the fourth child of
Petitioner and
Respondent

Q Psychological Report To prove that the

Respondent is
psychologically
incapacitated for the
purposes of marriage
with Petitioner,
suffering from
PERSONALITY
DISORDER
NARCISSITIC Type
and this disorder is
SERIOUS and GRAVE
and no amount of
therapy can effect a
change thereby the
condition is
INCURABLE and
PERMANENT.

R Resume of Visitacion To prove the

Revita qualifications of
Visitacion Revita as an
expert in the field of
psychology.

S Judicial Affidavit of To prove the purposes

Visitacion Revita stated in her Judicial
Affidavit and to
embody her direct
testimony with respect
to this case, as well as
to further prove that
the Respondent is
Pyschologically
Incapacitated to
perform the duties of

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 marriage.

Letter Invitation (Liham To prove that a letter

“T” to “T-2” Paanyaya sa was sent to the
Psychological Respondent inviting
Evaluation Test) her for psychological
addressed to Richell evaluation with
May Cosejo Ibarrola respect to this case.
and proofs of service

U Judicial Affidavit of To prove the purposes

Rosalyn Domingo stated in her judicial
affidavit and to serve
as his direct testimony
in this case.

V Judicial Affidavit of To prove the purposes

Realijean Cosejo stated in her judicial
affidavit and to serve
as his direct testimony
in this case.

That all the exhibits above-stated have been permanently

marked during the Preliminary Conference held before the Honorable
Clerk of Court.

PRAYER

WHEREFORE, it is respectfully prayed that this Honorable

Court admit the foregoing exhibits as part of the evidence for the
Petitioner. With the admission of the foregoing documentary
evidence, the Petitioner hereby rests.

Pakil, Laguna for Lucena City, Quezon, 8 July 2022.

ESGUERRA AND CAGAYAT LAW OFFICE

Counsel for the Petitioner
Pauline Bldg., 50 Tavera St., Pakil, Laguna
Tel. No. (049) 557-0231/Cel. No. 0922-8700457
esguerra_lawoffice10@yahoo.com

PABLO M. ESGUERRA
Attorney’s Roll No. 36979

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 PTR No. 9889006/01-03-2022
IBP No. 177330/02-07-2022
MCLE Compliance No. VI-0014491

NICOLO JUSTIN P. CAGAYAT

Attorney’s Roll No. 71786
IBP No. 169203, issued 1-2-2022
PTR No. 9855774/Paete, Laguna/1-3-2022
MCLE Compliance No. VII-0003645

Copy furnished:

PROSECUTOR ROWENA V. ARBOLEDA

Assistant Provincial Prosecutor
Office of the Provincial Prosecutor
Lucena City, Quezon

OFFICE OF THE SOLICITOR GENERAL

#134 Amorsolo St., Legaspi Village
Makati City

E X P L A N A T I ON
(Pursuant to Sec. 11 Rule 13 of the
1997 Rules of Civil Procedure)

The foregoing Formal Offer is being served by registered mail,

personal service not being practicable due to the distance between
the office of the undersigned and that of the counsel for the
Petitoner.

PABLO M. ESGUERRA