REPUBLIC OF THE PHILIPPINES

Regional Trial Court Branch 15

Pasig City

ROMEO RIVERA, petitioner Civil Case No. 2187-A

For: Declaration of Nullity
vs. of Marriage

JULIET JOAQUIN, respondent

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PRE-TRIAL BRIEF

PETITIONER, by counsel, respectfully submits his Pre-Trial Brief, as follows:

I. BRIEF STATEMENT OF PETITION

1.1 Petitioner pleads the court to declare the nullity of his marriage with the respondent due to
psychological incapacity.

II. FACTS AND OTHER MATTERS ADMITTED BY THE PARTIES

2.1. Petitioner admits that both him and respondent underwent psychological evaluation under the
same psychologist.

III. ISSUES TO BE TRIED

3.1. Plaintiff submits that the following issue is subject to proof:

3.1.1. The statement of cause the action in the petition.

3.1.2. The unawareness of respondent that she is under psychological evaluation affects the
findings of the psychologist

3.1.3. The psychological incapacity of the respondent

IV. EVIDENCE/WITNESSES:

4.1. Petitioner intends to present the following witnesses:

4.1.1 Dr. Jean Paul Gueco to establish the psychological incapacity of the wife present prior to the
celebration of the marriage.
4.1.2. Plaintiff reserves the right to present any and all documentary evidence, which shall become
relevant to rebut respondents claims in the course of trial as well as any other witnesses whose
testimony will become relevant to
belie defendants witnesses, if necessary.

VI. AVAILABLE TRIAL DATES

May 25, 2017, May 26, 2017, May 29, 2017.