corrected outline for direct examination

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Post on 07-Mar-2016

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this is the corrected direct examination on the case of declaring the husband of estela balagtas meravilla as presumptively dead.

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CORRECTED OUTLINE FOR DIRECT EXAMINATION1. Q. Madam witness, do you remember that you have executed a judicial affidavit in relation to your petition to judicially declare your husband presumptively dead?A. Yes.2. Q. Here is a judicial affidavit, will you please see and tell this honorable court, what is the relation of this judicial affidavit, that you have mentioned, as you have executed?A. (The counsel handed the judicial affidavit to the witness and the witness examined, in every page of the judicial affidavit). This is the judicial affidavit that I have executed sir.3. Q. Why you say so, that this affidavit which you have just saw and had examined, is your judicial affidavit? A. Because I affixed my signature in all the left margin of all the pages except on the last page which I affixed my signature right over the typewritten name of mine, in the said judicial affidavit.(Your honor, I would like to manifest, that the judicial affidavit which was identified by the witness as her judicial affidavit, executed in relation to her petition to declare judicially her husband presumptively dead, be mark as Exhibit A.)(Your honor, I would like to further manifest, that the judicial affidavit which was marked as Exhibit A be consider as the direct examination conducted to the witness in relation to her petition to declare her husband presumptively dead).(Your honor, may I proceed)4. Q. Madam witness, do you remember that you have secured a certification in relation to your earnest effort in ascertaining the whereabouts of your husband?A. Yes sir.5. From where those certification taken, to attest that you exerted earnest effort in ascertaining the whereabouts of your husband?A. First, from my in-laws Carlo L. Tuazon and Maria N Cantunes issued last 01 October 2015 then, the second was from the manager of the Evergreen Recruitment Agency issued last 01 November 2015 and the last certification was from the Legal Department of the POEA, Zamboanga city issued last 01 December 2015.6. Q. Showing to you, here three certifications, will you please see for yourself, if these were the very certification issued to you?A. (Witness examine the certifications) Yes these were the certification issued to me.7. Q. Why you say so that these certification were the very certification issued to you in relation to your earnest effort in ascertaining the whereabouts of your husband?A. Because, the certification bears my name as the one who requested it.(Your honor, I would like to manifest that the certification issued in different dates and places be marked as Exhibit B, C, and D respectively in accordance to the date of issue) (No further question your honor)