Republic of the Philippines

National Capital Judicial Region

Regional Trial Court
Branch 28
Makati City

PRISCILLA K. MA-ALINDOG
Complainant,

Criminal Case No: 1234567

- versus -

Complaint for: Violation of R.A 9262

Violence Against Women and their
Children

ARMANDO D. CAMACHO
Accused.

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

OFFER of TESTIMONY

The testimony of the witness is offered for the following purposes:

1. To testify as the Expert Witness in this case;

2. To prove the material allegations in the Petition; and
3. To testify on other matters relevant and incidental in this case.

JUDICIAL AFFIDAVIT OF CECILIA VILLANUEVA

I, witness Cecilia Villanueva, as an obstetrician gynecologist expert witness

for the private complainant Priscilla Ma-alindog, is Filipino, of legal age,
married to Robert Villanueva, and residing at #73 Soliven St. San Lorenzo
Village, Makati City after having been sworn in accordance with law, hereby
depose and state:

Q1: Mrs. Witness, please state your full name and personal circumstances.
A1: I am Cecilia Villanueva, 46 years old, and residing at ##73 Soliven St.
San Lorenzo Village, Makati City.
Q2: Mrs. Witness, what is this petition all about?
A2: This petition is for the violation of RA 9262 on the grounds of
psychological abuse with the aggravating circumstance of the victim
being pregnant at the time of commission of a crime.

Q3: How and when did you established connection with the victim?
A3: She was brought at the Ospital ng Makati on March 8, 2017 with the
critical condition of an incomplete abortion. I am the attending
physician as obstetrician gynecologist on the said. Hence, we
established a doctor-patient relationship.

Q4: Can you describe the condition of the victim when she arrived at the
hospital?
A4: At the onset, she was unconscious and feverish. I notice a severe
bleeding in the lower portion of her body as evidence by blood in her
clothes and legs. One of her companion stated that she was pregnant
and that she is complaining for a severe back pain. I initially made a
presumption of possible incomplete pregnancy, then examined the
victim and immediately subject her to ultrasound. Upon examination,
it is worth nothing that the victim is not in a healthy condition as
evidence by malnutrition.

Q5: What is the test that you have conducted and what is the result and
implication of such test? Can you please describe?
A5: Initially, I have ordered that the she be subjected to an ultrasound and
vaginal investigation. The test provided for a critical results such that
the fetus (1) has no sign of heart rate and (2) has no sign of any
movement. On the mother, she (1) was profusely bleeding internal and
external, (2) has an increate heart rate, (3) and is in critical condition
as she never responded to a viable delivery. To save her, I further
ordered that she be immediately subject to cesarean session to remove
the fetus inside.

Q6: In your findings what is/are the cause/s and effect/s of her condition?
A6: In summary, she experienced an incomplete delivery which resulted to
termination of her pregnancy. It is probable that such is cause by:
(1) probable consequence of trauma,
(2) infection of the reproductive organ or
(3) strong medicine intake.

…………………………………………………….

IN WITNESS WHEREOF, I have hereunto affixed my

signature this 28th day of March 2017 at the City of Makati, Metro Manila
Philippines.
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 CECILIA VILLANUEVA
Affiant

SUBSCRIBED AND SWORN TO before me this March 28, 2017 in Makati

City the following affiant exhibiting to me her Non-Professional Driver’s
License with license number NO2-094-55666 issued at LTO Central Office
on October 5, 2016 being sufficient and competent evidence of her identity
in pursuant to the 2004 Rules of Notarial Practice.

Doc. No.: 1457; PROSECUTOR

Page No. 58; NOTARY PUBLIC for Makati
Book No. III; Commission Serial No. 784351
Series of 2017. Until December 31, 2017
Roll of Attorney: 763218
IBP No. 8432567
PTR No. 8456271

I, ATTY. MANUELA RIGUERS, of legal age, Filipino, with postal address,

17th flr. New Makati City Hall, F. Zobel Street, Makati City, 1207 Metro
Manila after being duly sworn depose and say:

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1. I was the one who conducted the examination of Cecilia Villanueva at
my aforementioned office in 17th flr. New Makati City Hall, F. Zobel Street,
Makati City, 1207 Metro Manila;

2. I have faithfully recorded or caused to be recorded the questions I

asked and the corresponding answer that the witness gave;

3. I, nor any other person then present or assisting her coached the
witness regarding her answers;

IN WITNESS WHEREOF, I have hereunto set my hand this 28 th day of

March 2017 at Makati City, Philippines.

ATTY. MANUELA D. RIGUERS

Affiant

SUBSCRIBED AND SWORN TO before me this March 28, 2017 in

Makati, Philippines the following affiant exhibiting to me her Passport No.
N90754 issued at DFA NCR-EAST on July 23, 2015, being sufficient and
competent evidence of her identity in pursuant to the 2004 Rules of Notarial
Practice.

Doc. No.: 1460; Atty. Kayelyn Lat

Page No. 58; NOTARY PUBLIC for Makati
Book No. III; Commission Serial No. 784351
Series of 2017. Until December 31, 2017
Roll of Attorney: 763218
IBP No. 8432567
PTR No. 8456271

Copy Furnished:

Mr. Armando D. Camacho (Accused)

201 Astral Villa, Pililia St.,
San Antonio, Makati City

Atty. Wilma B. Riana (Counsel for Accused)

11th floor, Trafalgar Plaza, H.V. Dela Costa St.,
San Antonio Makati City