Cross Examination Questions

Counter Affidavit

3.7
 You said in the counter-affidavit that Dianne asked for a trial separation, did she
ever file any action pursuant to such?

3.17
 Who left for Singapore first? You or Dianne? [Although let’s clarify with Dianne
tomorrow who really did kasi if Kevin did that’s a win for us bai.]

3.25
 When you and Dianne were still living in Singapore, how was the relationship
between you, Dianne, and Andre with the other housemates? [Again, needs
clarification from Dianne tomorrow.]
o In your time there, did you experience any fights with the other housemates?
o Was there any time that Dianne fought with the other housemates while you
were there?
o So is it possible that what Katherine informed you were not true?

3.31
 You stated in your counter-affidavit that on September 7, 2011, you and Dianne
were in a hearing at the Regional Trial Court of Pasig City is that correct?
o What was the trial about?
o And it was the cross-examination of Dianne?
o You stated also that during the cross-examination Dianne admitted to be
negotiating in bad faith with regard to the written agreement outlining the
rights and responsibilities as parents, is that correct?
o What is your proof of that?
o Where the notes?
o [Ask the judge to put on record that the alleged stenographic notes proving
Dianne’s bad faith was not marked nor submitted as evidence bai.]

Opposition to Petition for Permanent Protection Order

1.6
 When did you start studying for your master’s degree in Singapore?
o How many years did you take to complete it?
o While completing your master’s degree in Singapore were you working at the
same time?
o If yes:
 What was your job?
 How long did you work for?
  How was the environment and working conditions?
o If no:
 How did you know about the work environment in Singapore?
 You never experienced the working conditions there personally?

1.13
 How do Dianne and Katherine know each other?
o How do you and Katherine know each other?
o When you and Dianne were still together, what was your relationship like?
 Did you hold hands in public?
 Did you hug in public?
 Would you guys make out in the presence of other people?
 [the line of questioning here is to establish that it was impossible for
Katherine to see Cai and Dianne kissing with Andres there as she
would not be open to PDA]

1.17
 [The line where it states, “… which Dianne did not deny in front of her own father,”
is detrimental to us. We should clarify this with Dianne tomorrow.]

1.21
 When Andre was still staying with you, did you ever hear him say that he wanted to
go home to his mother?
o Did you ever hear him say that he wanted to go back to Singapore?
o Did you ever hear him say that he didn’t want to stay with you?
 Did you ever hear Andre say that he didn’t want to go back to his mother?

7
 Is the name Juan Paolo Dela Cuesta familiar to you?
o How is he related to you?
o Has he spent a considerable amount of time with Andre?
o Have they bonded?
 When you made your facebook post addressing a letter to Andre, Mr. Juan Paolo
commented: “We’ll find that bitch Kev, don’t worry. I’ll beat her fucking face in with
my right fist till her teeth and brains leak out and I’ll do to the same to all her friends
and everyone she loves. No one fucks with us Kev, remember that!” Would you
consider that comment innocent?

Additional Questions
 When was the first time you met Cai?
o How would you describe her?
o Is it true that you became close to her while you and Dianne were will living
in Singapore?