Republic of the Philippines

REGIONAL TRIAL COURT

Second Judicial Region
Branch 20
Cauayan City, Isabela

KING GABRIEL
Petitioner,

-versus- CIVIL CASE NO. 20-3000

REINA GABRIEL
Respondent.
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PRE-TRIAL BRIEF

COMES NOW, petitioner, through counsel and unto this

Honorable Court most respectfully submits this Pre-Trial Brief,
as follows:

WILLINGNESS TO ENTER INTO AMICABLE SETTLEMENT

Petitioner is willing to enter into any agreement as may be

allowed by law;

STATEMENT OF THE CASE

Petitioner seeks a declaration of nullity of his marriage with the

respondent under Article 36 of the Family Code as the latter is
psychologically incapacitated to perform her essential marital
obligations and such psychological incapacity, which already
existed at the time of the celebration of their marriage, is grave,
permanent and incurable;

ISSUE/S
Whether or not petitioner’s marriage with the respondent should
be declared void ab initio on the ground of the respondent’s
psychological incapacity;

DOCUMENTARY EXHIBITS

Exhibit A: Notice of Appearance of the Office of the

Solicitor-General

ExhibitA-1: Letter of Deputation of the Office of the City

Prosecutor, Cauayan City, Isabela
Exhibit B: Order of the Court dated April 17, 2018 directing
the representative of the OSG to conduct
investigation on whether collusion exists between
the parties
Exhibit C: Certification of Non-Collusion
Exhibit D: Certificate of Live Birth of Princess Gabriel
Exhibit E: Certificate of Marriage between the parties
Exhibit F: Psychiatric Report (reserved)

Petitioner reserves his rights to present additional documentary

evidence as the need arises during the trial.

WITNESESS

1 Petitioner shall testify on the material allegations of the

petition to prove the psychological incapacity of the
respondent;
2 Doc Lina shall testify that based on her interviews and the
tests she administered, the respondent is psychologically
incapacitated to perform her essential marital obligations;

Petitioner reserves his rights to present additional witnesses as

the need arises during the trial.

MODES OF DISCOVERY
Petitioner reserves his rights to avail of the Modes of Discovery
provided by the Rules of Court as the need arises during the
trial.

Respectfully submitted.
Roxas, Isabela, October 29, 2018

ATTY. LINO LOKO

Counsel for the Petitioner