Professional Documents
Culture Documents
ERIC C. CONSUNJI
Petitioner,
KIMMY I. DORA.
Respondent.
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3.1 The payment slips and work orders show that Respondent was employed
as a night worker;
3.2 The psychological report establishes Respondents anti-social
personality disorder and narcissistic personality.
3.3 The billing statement and receipts from the Droga Foundation show that
Respondent was confined in the foundation before and during their
marriage.
3.4 The medico-legal report conducted by Dr. Villanueva and the Order of
Dismissal of the Parricide case shows how petitioner was stabbed by the
respondent.
3.5 The police blotter reported by Marvin Magdangal shows the indifferent
attitude of respondent over the deaths of the victims.
3.6 The passbook entries show that Petitioner has been consistent in
providing support for the Respondent and their children in amount of
two hundred thousand pesos (Php 200,000) per month
3.7 The case study establishes the improbability of reconciliation between the
spouses and the recommendation for nullity of marriage.
III. ISSUE
4 Petitioner proposes the following factual and legal issues for resolution:
4.1 Whether or not respondent is psychologically incapacitated.
4.2 Whether or not the petition for nullity of marriage may prosper in
accordance with Art. 36 of the Family Code and the Molina doctrine
based on the respondents psychological incapacity.
Exhibit S Aug. 17, 2017 Payment Slip for To show that the
DSWD case study
conducted by Ms.
Alejo was coursed
through the
DSWD, a
reputable
government
institution.
Exhibit T Medico Legal To show that Eric
Certificate for was gravely
Stab Wound injured by
Kimmys attack
and parricide
attempt
Exhibit U March 3, 2012 Police Blotter for To show
Accident respondent being a
party to an
accident due to
reckless driving
under the
influence of
alcohol.
Exhibit V Aug. 3, 2012 Medico-Legal To show that
Certificate for Kimmy had
Accident severely impaired
facilities at the
time of the driving
accident.
Exhibit W June 23, 2010 OR/CR and Car To establish Eric
Registration of as the owner of the
BMW car
Exhibit X March 9, 2013 Mortgage To establish the
Agreement measly amount
Kimmy mortgaged
the car for
Exhibit Y March 9, 2013 Withdrawal Slip To establish that
Php 65,000 was
indeed withdrawn
from Jose Ignatius
Exhibit Z Deed of Sale (For To show that
Valenzuela Lot) Kimmy Consunji
attempted to sell,
without the
consent of her
husband Eric, a
Valenzuela
Property owned by
the spouses
Exhibit AA May 20, 2011 Pawn Ticket To show that
Receipt defendant pawned
family jewelry
Exhibit BB May 13, 2012 Payment Slip for To show that
Pawn Ticket Petitioner paid for
the pawn debt
contracted by
Kimmy
7 Petitioner reserves his right to present (a) the foregoing documents for
purposes other than those state above; and (b) other relevant documents not
presently available or as may be necessary in the course of the trial.
VI. WITNESSES
8 Plaintiff will present the following witnesses:
RESPECTFULLY SUBMITTED
Copy furnished: