DIRECT EXAMINATION OF ATTY PALADAN TO QD EXPERT JOHNY TUMALIUAN

Paladan/Nogoy: What is your participation in this case mr witness?

QD expert: I am the Questioned Document Expert hired by Ms Monsher Tan to prove the
authenticity of the signature of the decedent and the instrumental witnesses in the will
and the handwriting in the letter made by the decedent before her death
Paladan/Nogoy: What do you call this examination and how is it done?
QD expert: The examination is called Detailed Microscopic Comparative Examination.
Whenever the handwriting or signature is in question, all specimen will be examined under
the special microscope to see the nature of the specimen if it is authentic or signed by one
and the same person and how it is being executed.
Paladan/Nogoy: Under this examination what is the result of your findings on
the signature of Jaimie Tan in the will, Mr witness?
QD Expert: According to my study, it was indeed the signature of Ms. Jaimie Tan since it
contains strokes and hit which are one and the same as the letter and series of IDs and
documents that Ms. Monsher showed me
Paladan/Nogoy: Is that all in your findings?
QD Expert: Only, the stroke of the handwriting according to my findings has some
inconsistencies as to marking since there was a gap, stoppage and series of pen lifts in the
signature, meaning the signature was not done in a simultaneous way.
Paladan/Nogoy: What do you mean when you say there are some
inconsistencies, gap and series of pen lifting in a laymans term?
QD Expert: Meaning that there is an indication that the one writing might be stopping
when signing the document since there is no continuity as to the stroke. It also seems
likely that the signature was done in a slow manner as to the stroke of the letters which is
odd to see on normal signature of a person done with continuity.
Paladan/Nogoy: Is that all in your findings?
QD Expert: Also, the signature of Wilfredo Tan, Dr Leona Mangahas, Atty Leila de Lima, and
Brgy Captain Jesusa Mangurnong in the notarial will have the same strokes, pen lifts and
pen pressure
Paladan/Nogoy: Meaning it indicates what mr witness?
QD Expert: It means that the signature is done by the same handwriting.
Paladan/Nogoy: Meaning the signature of Wilfredo Tan, Dr Leona Mangahas,
Atty Leila de Lima, and Brgy Captain Jesusa Mangurnong in the notarial will is
done by the same person? Is that what you want to tell us?
Lanuza: Objection! Misleading!
*OVERRULED
*SUSTAINED
Repeat
Change
(Sasagot lang pag sinabi ni Judge na Overruled)
QD Expert: Yes mam
Paladan: YH I just repeated the answer of the QD Expert and Iam just giving
emphasis that the signatures on the notarial will came from one and the same
handwriting YH as what the QD expert has examined.
Paladan/Nogoy: Is this the Last Will and Testament that you have examined?
Lanuza: Objection! Not the best evidence!
*OVERRULED
*SUSTAINED
Repeat

Change
(Sasagot lang pag sinabi ni Judge na Overruled)
QD expert: Yes mam this is the Last will and testament I examined
Paladan/Nogoy: But YH, this is the original document furnished by the petitioner
to the oppositor and this was presented during pre trial and the good counsel
here did not even object YH
Paladan/Nogoy: You honor I have here the copy of the Last Will and testament of
the decedent and we wish that this be maintained and marked as Exhibit 1
Paladan/Nogoy: Is this the result or findings of the Detailed Microscopic
Comparative Examination you are referring to?
QD Expert: Yes mam
Paladan/Nogoy: Your honor I have here the copy of the result or findings of the
Detailed Microscopic Comparative Examination executed and evaluated by the
expert witness himself and we submit this document and we wist to retain the
marking of this evidence as Exhibit 2 your honor
Paladan/Nogoy: Mr Witness, How about the letter made by the decedent before
her death? Can you tell us what your findings are?
QD Expert: the letter that I have examined under the microscopic examination has
identical lift, stroke, style and form as to the handwriting of the decedent. It is the same as
the handwriting of Ms Jaimie Tan
Paladan/Nogoy: What is your basis in comparing the handwriting of the
decedent in the letter to say that in deed such handwriting belongs to the
decedent?
QD Expert: Monsher Tan gave me series of handwriting of Jaimie Tan that would serve as
my basis and comparison to conclude that such handwriting is authentic.
Paladan/Nogoy: So what is the result of your examination?
QD Expert: The result of my findings is that the handwriting in the letter is the same as the
handwriting of Ms Jaimie Tan
Paladan/Nogoy: Is this the result or findings of the Detailed Microscopic
Comparative Examination you are referring to with regard to the handwriting of
the decedent in her letter?
QD Expert: Yes mam
Paladan/Nogoy: Your honor I have here the copy of the result or findings of the
Detailed Microscopic Comparative Examination executed and evaluated by the
expert witness himself and we submit this document and we wish to maintain
the marking of this evidence as Exhibit _________ your honor
Thats all your honor!
CROSS EXAMINATION BY ATTY LANUZA
Lanuza: Mr witness you declared to be a Questioned Document Expert?
Johny: Yes sir
Lanuza: How long youve been practicing this kind of profession?
Johny: 10 years as private practitioner sir
Lanuza: You testify that you are hired by Ms Monsher. How much did she pay you?

Paladan: Objection Your Honor! Irrelevant the question has no relation to the
case! And besides theres nothing wrong for such payment as the witness is a
private practitioner and he do it for a business in order to earn for a living.
*OVERRULED
*SUSTAINED
Repeat
Change
(Sasagot lang pag sinabi ni Judge na Overruled)
Johny: This is business of course..5 thousand per examination sir
Lanuza: How are you related to Monsher Tan?
Paladan: Objection Your Honor! Irrelevant! What is the connection of the
relationship of Monsher to the Questioned Document Expert in this case?
*OVERRULED
*SUSTAINED
Repeat
Change
(Sasagot lang pag sinabi ni Judge na Overruled)
Johny: I do not know her personally sir. She just came to my office and asked me if I can
examine the last will and testament of her sister
Possible question of Judge: Do you have the copy of the Last will and
testament?
Johny: Yes sir Ms monsher gave it to me. According to her she was furnished a
copy of the original by the executor of the last will.
Lanuza: Did she tell you that you will be testifying in court regarding the Last will and
testament of Ms. Tan?
Johny: Yes sir thats but normal to my profession because we are considered as expert
witness with our field. And iam used to it.
Lanuza: Did she talk to you before you sit in the witness stand?
Paladan: Objection Your Honor! Irrelevant!
*OVERRULED
*SUSTAINED
Repeat
Change
(Sasagot lang pag sinabi ni Judge na Overruled)
Johny: Of course not sir. Why she will do that and what for? All my testimony here is just
based on my findings and examination nothing personal sir.
Lanuza: You also testified that you examine the Last Will and Testament of Ms. Tan. Am I
correct?
Johny: Yes sir
Lanuza: And that you examined is a photocopy of the last will and testament of Ms. Tan.
Am I correct?
Paladan: Objection Your Honor! Misleading! We already presented the copy and
it was marked as Exhibit____during the pretrial and during on direct
examination! I think the good counsel here is fond of speculating things YH!
*OVERRULED
*SUSTAINED

Repeat
Change
(Sasagot lang pag sinabi ni Judge na Overruled)
Johny: No sir because the last will and testament I examined has original signatures.
Possible question of Judge: Do you have the copy of the Last will and
testament?
Johny: Yes sir Ms monsher gave it to me. According to her she was furnished a
copy of the original by the executor of the last will.
Lanuza: So that you never saw the original Last Will and testament of Ms. Tan
Paladan: Objection Your Honor! Misleading! YH May we enter our continuing
objection! As the good counsel here is fond of speculating things without basis!
No further question YH