Republic of the Philippines
9th Judicial Region
MUNICIPAL TRIAL COURT IN CITIES
LAMITAN CITY
Province of Basilan
AILEEN AGUILAR SANSON CIVIL CASE NO. 564
Plaintiff,
-for-
-versus-
MORAL DAMAGES
MARIE LHEN P. SANSON under Art. 2219 in relation
Defendant. to Art. 26 (2) of the New
Civil Code
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JUDICIAL AFFIDAVIT of WITNESS
WITNESS: NAME - CARMELITA NAVA SANSON
ADDRESS - Sitio Tinog, Barangay Ubit, Lamitan City, Basilan
OCCUPATION - Housewife
OFFER OF TESTIMONY: The testimony of the witness is being offered to prove
and corroborate the material allegations on the following relevant points:
1. That the Plaintiff and her husband, Joseph, used to lead a happy and
peaceful family life and very seldom quarrelled;
2. That as a result of the discovery of the chat messages between Defendant
and Katherine, the Plaintiff and the latter’s husband GRAVELY quarrelled
over the phone; and
3. That this witness was the one who tried to mend the fences between
Plaintiff and the latter’s husband;
4. That Joseph who was then working abroad as a seaman called this
witness and told her that Joseph entertained suicidal thoughts due to the
stress caused by the quarrel between the spouses
5. Such other matters as maybe relevant to the Plaintiff’s cause of action
I, CARMELITA NAVA SANSON, of legal age, widow, Filipino Citizen and
with address at Sitio Tinog, Barangay Ubit, Lamitan City, Basilan, Philippines,
under oath, do hereby depose and state that:
PRELIMINARY STATEMENT
ATTY. RAUDA I. SALISA, with office address at Seaside Barangay,
Isabela City, Basilan, conducted my examination as a witness at her law office. I
am answering the questions asked of me fully conscious that I do so under oath
and may face criminal liability for false testimony and perjury.
QUESTIONS AND ANSWERS
Q1: What is the reason for your presence here today?
A1: I am here to testify on what I know regarding the case filed by Aileen Sanson
against Marie Lhen Sanson.
Q2: Do you know the Plaintiff in this case?
A2: Yes. I know Aileen as she is my daughter-in-law. She is married to my son
Joseph N. Sanson.
Q2: Do you also know the Defendant in this case?
A2: Yes, I know Marie Lhen Sanson as she is the niece of my late husband. She
is the cousin of Joseph. Hence, she is the cousin-in-law of the Plaintiff.
Q3: How do you describe the Plaintiff and Joseph’s marital life?
A3: As far as I know the Plaintiff and Joseph lived as a happy couple. They
rarely quarrelled or fought. Most of the time, they lived harmoniously and
peacefully together.
Q4: Were there instances when the spouses quarrelled?
A4: I know only two instances where they quarrelled.
Q5: What caused the first quarrel?
A5: The first quarrel was due to a woman named KATHERINE. From what I
know, Katherine was Joseph’s high school schoolmate. When Joseph was in
Manila to take her Marina Licensure Exam, he had flirtatious exchange of
messages with Katherine through text and chat. When Plaintiff learned of this,
she confronted Joseph and they had a serious quarrel.
Q6: Did the Plaintiff and her husband resolve the matter of this first quarrel?
A6: Yes. Joseph went home to Lamitan City just to apologize for his
shortcomings as a husband. The Plaintiff forgave Joseph and they lived happily
as a couple again.
Q7: What caused the second quarrel?
A7: The second quarrel was caused mainly by Defendant, Marie Lhen Sanson.
The Plaintiff told me that the Defendant used the mobile phone of Plaintiff’s
son, John Uriel to chat with Katherine. I also learned from the Plaintiff that
Defendant used to give Katherine information and updates regarding the
activities of Joseph. I likewise learned that Defendant urged Katherine to
persuade Joseph to meet up in Manila.
Q8: When did the second quarrel happen?
A8: Sometime in February 2020.
Q9: How do you describe this second quarrel that transpired between the
spouses?
A9: It was way graver than the first quarrel. I heard the Plaintiff and Joseph
quarrel over the phone many times in the next few days after the incident of the
discovery of the chat messages.
Q10: What made you say so?
A10: In their first quarrel, I did not need to bridge the gap between the spouses.
In this second quarrel, my son Joseph called me many times and told me to talk
to Plaintiff and explain to the latter that he had done nothing wrong. Joseph told
me that the hardship that he was experiencing at work was greatly worsened by
their marital misunderstanding.
Q11: Did you talk to the Plaintiff also?
A11: Yes. When I talked to the Plaintiff, the latter said it might be better if she
separated from Joseph. I tried to pacify the Plaintiff and explain that Joseph did
not do anything wrong and that in fact, Joseph already turned down Katherine’s
invitation to meet up as shown by the chat messages.
Q12: What was the reaction of the Plaintiff?
A12: During our talk, it was apparent that the Plaintiff was terribly hurt by the
Defendant. Plaintiff appeared restless and haggard for a number of days.
During those days she kept talking to me about the Defendant and how the latter
shamelessly used the mobile phone of Plaintiff’s son to chat with Katherine. She
kept telling me that it was impossible for her to forgive Defendant for the latter’s
act of disturbing the peace of her household in return for a meagre amount of cell
phone load.
Q13: What happened after that?
A13: After a day or two, Joseph called me and told me he could no longer bear
the stress of the work and his family problem. Joseph even told me that he was
already entertaining suicidal thoughts and that only the thought of his three
children kept him from bringing those dangerous thoughts to reality.
Q14: How did the Plaintiff react to this?
A14: When I relayed Joseph’s conversation with me to the Plaintiff, the latter
became inconsolable at first. She was crying heavily.
Q15: What happened after that?
A15: Finally, after a few weeks, Plaintiff was able to pull herself together and
calmly talk to Joseph through the phone. I was glad when I learned that Plaintiff
had forgiven Joseph.
Q16: What happened after the spouses reconciled?
A16: Although the spouses reconciled, Plaintiff told me that she would still lodge
her complaint with the Barangay Officials against the Defendant. She also said
that if the issue is not resolved in the Barangay Office, she would file the
necessary case against the Defendant because the latter cannot be allowed to
get away with her transgressions.
Q17: Do you have anything more to say?
A17: No more.
In witness whereof, I have hereunto set my hand this 16th day of October,
2020 in the City of Isabela, Philippines.
CARMELITA NAVA SANSON
Affiant
Subscribed and sworn to before me this 19th day of August, 2020 in the
City of Isabela, Philippines.
Doc. No. ____;
Page No. ____;
Book No. ___;
Series of 2020
ATTESTATION
I, ATTY. RAUDA I. SALISA, of legal age, Filipino, single, and with office
address at Seaside Barangay, Isabela City, Philippines, do hereby depose and
state, that:
1. I faithfully recorded or caused to be recorded the questions asked and
the corresponding answers that the witness gave in accordance with
Section 4 of A.M. No. 12-8-8-SC otherwise known as the Judicial
Affidavit Rule;
2. Neither I nor any other person then present or assisting with the above-
stated Judicial Affidavit coached the witness regarding the answers
given by the latter;
3. I am executing this Affidavit to attest to the authenticity, genuineness,
and veracity of the facts laid down in the above Judicial Affidavit of the
witness for whatever legal purpose it may serve within the boundaries
set forth by law.
IN WITNESS WHEREOF, I have hereunto affixed my signature this 14 th
day of October, 2020 in the City of Isabela, Philippines.
ATTY. RAUDA I. SALISA
IBP No. 06-9846-01-01/17/2019
Subscribed and sworn to before me this ___ day of _______, 2020 at the
City of Isabela, Philippines.
