Republic of the Philippines

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
Branch __, Las Pinas City

EDUARDO O. DAMAYO,
Petitioner,

-versus- Civil Case No.________

For: Declaration of
Nullity of Marriage
MA. KRISTINE S. NARAJA-
DAMAYO,
Respondent.
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PETITIONER’S PRE-TRIAL BRIEF

Petitioner, through the undersigned, into this Honorable
Court, respectfully states that:

I. POSSIBILITY OF A SETTLEMENT AND SUBMISSION OF

THE CASE TO ANY OF THE ALTERNATIVE MODES OF
DISPUTES RESOLUTION:

Petitioner is willing to enter to any possible

amicable settlement and/or submit to alternative
modes of dispute resolution except on matters
prohibited under Section 16 of the Rule on Declaration
of Absolute Nullity of Void Marriages and Annulment of
Voidable Marriages.

II. PROPOSAL FOR ADMISSION AND STIPULATION:

The stipulation and admission is hereby proposed

follow:
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 Would the respondent admit the due existence of
the Psychological Examination Report by Dr. Nikki
Garcia?

III. ISSUE TO BE HELD AND/OR RESOLVED:

Whether or not the marriage of the petitioner to

the respondent should be declared null and void due to
the psychological incapacity of the respondent

IV. APPLICABLE LAWS AND JURISPRUDENCE

Pertinent provisions of the Family Code

(particularly Articles 68, 70 and 72), Supreme Court
Circular on the Rules of Absolute Nullity and Void
Marriages and Annulment of Voidable Marriages and
related Jurisprudence

V. DOCUMENTARY EXHIBITS TO BE PRESENTED DURNG THE

TRIAL

a) Exhibit “A” Marriage Contract between

petitioner EDUARDO O. DAMAYO
and MA. KRISTINE S. NARAJA on
February 14, 2014.

b) Exhibit “B” The Psychological Examination

Report of MA. KRISTINE S.
NARAJA by Dr. Nikki Garcia.

c) Exhibit “C” Judicial Affidavit of the Petitioner

We reserve other documents that will be allowed by

this Honorable Court.

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VI. WITNESSES:

The petitioner will present the following witnesses:

1. Petitioner himself;

2. Dr. Nikki Garcia- the psychologist made the

examination;

3. Reservation as to other witnesses.

VII. AVAILABLE TRIAL DATES:

As may be agreed upon by the parties, subject to

the schedule of this Honorable Court

Respectfully submitted.
January 30, 2019, in Las Piñas City.

ATTY. CHRISTINE JANE A. RODRIGUEZ

Counsel for the Petitioner
BF Homes Village, Paranaque City,
Roll No. 258369
IBP No. 01231995
PTR No. 12365498
MCLE Compliance No. 1203456
Tel. Nos. 862-2366; 862-2367
christinejanerodriguez23@gmail.com

EXPLANATION

A copy of this Pre-trial brief was served upon the

parties concerned by way of registered mail due to
considerable distance and lack of manpower to serve
pleadings personally.

ATTY. CHRISTINE JANE A. RODRIGUEZ

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