Vous êtes sur la page 1sur 2

Stipulation of Facts:

1. Will the defendant admit the personal circumstances of the petitioner? That he is a resident of Brgy.
Kamagayan, Cebu City?
2. Will the defendant admit that on January 7, 2005, petitioner and defendant contracted a marriage
at the office of the City Mayor of Cebu when they were 23 and 22 years old?
3. Will the defendant admit that in 2004, petitioner was working as a technician at the Cebu Mitsumi
Inc. in Danao City, Cebu? And became acquainted with the defendant who was working as a
production operator on a contractual basis of the same company?
4. Will the defendant admit that the brief acquaintance of the petitioner led to an amorous relationship
that resulted to the pregnancy of the defendant?
5. Will the defendant admit that 3 months after the celebration of their wedding, on April 25, 2005,
Eden Mae S.Go, their daughter, was born?
6. Will the defendant admit that during their marriage, when the petitioner and defendant lived together
as husband and wife, petitioner became acquainted with defendant’s personal traits, and
idiosyncrasies? That the petitioner discovered that defendant is utterly insensitive, foul-mouthed,
spendthrift, irresponsible and highly incapable of performing her essential marital duties and
obligations?
7. Will the defendant admit that the petitioner sought greener pastures for their family, by working in
Saudi Arabi since 2008?
8. Will the defendant admit that during the time when petitioner was in Saudi, the defendant became
wasteful and excessive in her spending?
9. That’s all your Honor.

Issues:

Whether or not defendant is psychologically incapacitated to perform her essential marital duties and
obligations.

Whether or not grounds exist for the declaration of the nullity of marriage of the petitioner with the defendant
pursuant to Art. 36 of the Family Code of the Philippines.

Whether or not petitioner should be granted visitation rights specially within the yearly 30-day visit in the
country while being an Overseas Filipino Worker [OFW] and on a regular basis as well in the future as his
biological father of Eden Mae S. Go.

Whether or not defendant should be required to render an accounting and breakdown of the expenditures
of the monthly allowance that the petitioner is sending his son to serve as deterrent for further extravagance
and misappropriation of monthly sustenance of the child.

Witnesses:

With the permission of this Honorable Court. Your Honor, the petitioner will present three (3)
witnesses: petitioner himself together with witness Maria Corazon Villarosa and a psychologist. They will
be presented to support the allegations in the Petition. This will take around thirty (30) minutes each. The
presentation of a rebuttal witness will depend on the necessity thereof and this will also be contingent on
the flow of the evidence to be presented by the defendant. Petitioner also reserves the right to present
additional witnesses as the need arises.

Marking of Exhibits:
With the permission of this Honorable Court. Your Honor, the petitioner will present the following
documentary evidence and mark as petitioner’s exhibits:

Exh. “A”: Barangay Clearance as proof of petitioner’s residency in Barangay Carmen, Toledo City,
Cebu;

Exh. “B”: Certificate of Marriage issued by the Office of the National Statistics Office evidencing the
fact of marriage on 07 January 2005 at the Office of the City Mayor of Cebu City, Philippines;

Exh. “B-1”: Original Official Receipt of the Issuance of the NSO Certificate of Marriage;

Exh. “B-2”: Photocopy of the Official Receipt of the Issuance of the NSO Certificate of Marriage;

Exh. “C”: Certificate of Live Birth of Eden Mae S. Go who was born on 25 April 2005 in Cebu City,
Cebu, Philippines;

Exh. “C-1”: Original Official Receipt of the Issuance of the NSO Certificate of Live Birth;

Exh. “C-2”: Photocopy of the Official Receipt of the Issuance of the NSO Certificate of Live Birth;

Exh. “D”: Judicial Affidavit of the petitioner, Mr. Mikey GO, consisting of 12 pages to be marked as
Exh D-1 to D-12.

Exh. “E”: Judicial Affidavit of the witness, Jesther Rose Go, consisting of 7 pages to be marked as
Exh E-1 to E-7 and

Exh. “F”: Judicial Affidavit of the psychologist, Dr. Veron Dalumbar consisting of 9 pages to be
marked as Exh F-1 to F-7.

Your Honor, a reservation is made for the production and marking of additional documents in the course of
the hearing of the case.