Pre-Trial Brief (Declaration of Nullity of Marriage)
Pre-Trial Brief (Declaration of Nullity of Marriage)
Pre-Trial Brief (Declaration of Nullity of Marriage)
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mother which manifested after the death of respondents
father in 2005; e) that said disorder is mild and curable, and
does not interfere with his proper functioning as a husband;
g) that respondent is still capable of complying with his
marital obligations.
PROPOSED STIPULATION OF FACTS
1. The identity of parties: Sunshine Mae Maligalig
petitioner and Jorge Manuel Maligalig as respondent;
as
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ABSTRACT OF TESTIMONIES
KATARINA P. DEL SOL, a close and long-time friend of
the petitioner and respondent, who will testify on the
relationship of the spouses as husband and wife.
BRO. RUDOLFO Y. DEMETRIO the Advocate of the
National Appellate Matrimonial Tribunal of the Catholic
Church in the Philippines will be testifying on
contemporaneous religious interpretation.
DR. HERMOSA PADILLA, the psychiatrist who will
testify on the psychiatrical report done on respondent.
RESERVATION
The Solicitor General respectfully reserves the right to
present other evidence and/or witnesses as the necessity
thereof may arise.
ADMISSIONS
Outside of the matters alleged, the solicitor general is
not inclined to admit further matters.
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PROPOSED ISSUES
1. Whether
or
not
respondent
is
psychologically
incapacitated to comply with the essential requisites of
marriage which is a valid ground under Art. 36 of the New
Family Code to declare the marriage a nullity.
2. Whether collusion exists between the parties.
RESPECTFULLY SUBMITTED.
City of Manila. February 4, 2016.
Signed by:
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FLORIN T. HILBAY
Solicitor General
Copy furnished:
ATTY. AAA BBB
Counsel for Plaintif
6750 Fairmont Mansion,
Makati Avenue, Makati City
ATTY. IIGO ACUZAR III
Counsel for Respondent
25/F ACCRALAW TOWER
Second Avenue corner 30th Street,
Crescent Park West Bonifacio Global City,
0399 Taguig, Metro Manila, Philippines
EXPLANATION
(Re: Service thru Registered Mail)
Pursuant to the Provision of Rule 13, Section 11 of the
1997 Rules in Civil Procedure as Amended, undersigned
submits this Explanation that the service of this Pre-Trial Brief
was by Registered Mail instead of personal serve in view of
lack of manpower.