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Formal Offer of Evidence in Marriage Nullity Case

Petitioner Anna Liza Garcia-Chamorro formally offers various documentary exhibits to the court for the purposes of proving key facts in her case for declaration of absolute nullity of marriage to Respondent Baby Boy Chamorro. The exhibits include marriage certificates, birth certificates, court decisions and affidavits that aim to demonstrate Petitioner's prior existing marriage to Gerardo Alvarado and the nullification of that marriage, as well as the circumstances of her marriage to Respondent.
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0% found this document useful (0 votes)
85 views6 pages

Formal Offer of Evidence in Marriage Nullity Case

Petitioner Anna Liza Garcia-Chamorro formally offers various documentary exhibits to the court for the purposes of proving key facts in her case for declaration of absolute nullity of marriage to Respondent Baby Boy Chamorro. The exhibits include marriage certificates, birth certificates, court decisions and affidavits that aim to demonstrate Petitioner's prior existing marriage to Gerardo Alvarado and the nullification of that marriage, as well as the circumstances of her marriage to Respondent.
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd

Republic of the Philippines

National Capital Judicial Region


REGIONAL TRIAL COURT
Marikina City
Branch 192

ANNA LIZA GARCIA-CHAMORRO,


Petitioner,

CIVIL CASE NO. 11-2147-MK


-versus- For: Declaration of Absolute
Nullity of Marriage

BABY BOY A. CHAMORRO,


Respondent.
x --------------------------- -- x

FORMAL OFFER
OF DOCUMENTARY EXHIBITS

PETITIONER, through the undersigned counsel, unto this


Honorable Court hereby formally offers the following exhibits for the
purposes stated hereunder:

EXHIBIT DESCRIPTION PURPOSE


A Marriage Certificate of To prove that Petitioner and
Petitioner Anna Liza Respondent contracted marriage
Garcia and Respondent on November 23, 2000 at the
Baby Boy Chamorro Office of the Mayor, Antipolo
City.
B Birth Certificate of Tristan To prove that during the
Jabez Garcia marriage, Petitioner and
Respondent begot a son named
Tristan Jabez Garcia, who was
born on January 28, 2003.
C NSO copy of the Marriage To prove that Petitioner first
Contract of Petitioner contracted marriage with
Anna Liza C. Garcia and Gerardo C. Alvarado on July 27,
Gerardo C. Alvarado 1989 at the Club Filipino,
Greenhills, San Juan, solemnized
by Pastor Salvador T. Palma.
C-1 Remarks on the Marriage To prove the fact and regularity
Contract between Gerardo of the National Statistics Office’s
Alvarado and Ana Liza recording the Remarks
Garcia “Pursuant to the Decision dated

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March 22, 2001 rendered by
Judge Franchito N. Diamante of
the Regional Trial Court
National Capital Judicial Region
Branch 151, Pasig City, under
JDRC Case No. 4007, the
marriage between the herein
parties celebrated on July 27,
1989 is hereby declared null and
void ab initio”.
D Certification from the To prove that a Decision was
Office of the Civil rendered by Judge Franchito N.
Registrar of San Juan, Diamante of RTC-NCJR, Branch
151, Pasig City dated March 22,
2001 Re declaration of Nullity of
Marriage between Gerardo
Alvarado and Ana Liza Garcia-
Alvarado on July 27, 1989 at
Club Filipino, Greenhills, San
Juan. This fact was recorded by
the Civil Registrar under
Registry No. 2003- 29 Series of
2003.
D-1 Certified Xerox Copy of To prove that Petitioner
the Marriage Contract of contracted marriage with
Petitioner Anna Liza C. Gerardo C. Alvarado on July 27,
Garcia and Gerardo C. 1989 at Club Filipino, San Juan
Alvarado and said marriage was recorded
in the Office of the Civil
Registrar of San Juan.
D-2 Certification from the To prove that the Decision
Office of the Civil promulgated by the RTC-NCJR,
Registrar, City of Pasig Branch 151 of Pasig City,
presided by Judge Franchito N.
Diamante in JDRC Case No. 4007
issued on March 22, 2001, the
marriage entered into by and
between Gerardo Alvarado and
Anna Liza Garcia- Alvarado on
July 27, 1989 as NULL and
VOID, has been filed and
recorded with the Office under
Reg. No. 2003-34, Series of 2003
on June 10, 2003.
D-3 Certification from RTC- To prove that the decision dated
NCJR Branch 151 dated March 22, 2001 in JDRC Case No.

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June 14, 2001 4007 has become final and
executory as there is no appeal
or objection thereto.
D-4 Decision in JDRC Case No. The Certified Xerox/true copy of
4007 from the RTC-NCJR the Decision on record of the
Branch 151, Pasig City Local Civil Registrar proves the
dated March 22, 2001 by fact of existence on record of a
Judge Franchito N. decision rendered by the court in
Diamante the case.
D-5 Affidavit of Late To prove that Gerardo Alvarado
Registration of Gerardo was not able to immediately
Alvarado field before the cause the filing of the Decision in
Office of the Local Civil JDRC Case No. 4007 with the
Registrar of Pasig City Office of the Local Civil Registry
dated June 10, 2003 because he was not informed by
his counsel to cause the filing of
the same
E Judicial Affidavit of Anna To prove that, in the course of
Liza Garcia-Chamorro the trial and as part of her
testimony, Petitioner has
executed a judicial affidavit
describing the circumstances
prior to and during her marriage
with Respondent, as well as
those which eventually led to
their separation. Petitioner gave
more emphasis on the aspect of
having contracted a second
marriage without knowledge
that the first marriage was still
existing then.
E-1 Signature of Ana Liza To prove that Petitioner affirms
Garcia-Chamorro and confirms the contents of her
judicial affidavit
L Certification dated To prove and confirm the
February 12, 2014 from the testimony of witness, Ms.
National Statistics Office Esperanza D. Zapanta from the
National Statistics Office that
upon verification on their
records regarding the death of
Gerardo Alvarado, the same
yielded negative results.

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Undersigned counsel respectfully submits with this Formal Offer of
Evidence the original documents marked as Exhibits “A”,”B”,”C”,”D”,”E”,
and “L” with submarkings.

PRAYER

WHEREFORE, it is most respectfully prayed of this Honorable Court


that Exhibits A,B,C, D, E, and L with submarkings be admitted for the
purposes for which they are being offered.

Such other reliefs just and equitable under the premises are likewise
prayed for.

RESPECTFULLY SUBMITTED. Pasig City for Marikina City. 04


March 2014.

REP LAW PHILIPPINES


Rodriguez Esquivel Palpal-latoc
Law Firm
(Formerly The Rodriguez & Partners Law Firm)
Counsel for Petitioner
Suite 1505 Mega Plaza Bldg.
ADB Avenue corner Garnet Road
Ortigas Center, Pasig City
Tel. Nos. (+632) 570-7719;570-8512
Email address: [email protected]

MARIA ANGELA N. ESQUIVEL


IBP Lifetime Roll No. 08091
PTR No. 9042442 – January 2, 2014 – Quezon City
MCLE Compliance No. IV-0011025, 01-03-13
Roll of Attorney No. 50464

RENELYN J. ARELLANO
IBP Number 953005- Bulacan Chapter/ January 7, 2014
PTR No.2730035-Valenzuela City/January 3, 2014
Roll of Attorneys No. 60797
MCLE Compliance No.IV-0016819, 04-12-2013

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Copy furnished:

Baby Boy A. Chamorro


Blk. 1, Lot 49, Jaka Village,
San Pedro, Laguna

Office of the Solicitor General


134 Amorsolo St.,Legaspi Village
Makati City

Office of the City Prosecutor


Hall of Justice
Quezon City

EXPLANATION

This Formal Offer of Evidence will be filed with the Honorable Court
and copy thereof to the above addressees via registered mail, personal
service being impracticable for lack of material time.

RENELYN J. ARELLANO

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