Republic of the Philippines National Capital Judicial Region REGIONAL TRIAL COURT Branch 156 Marikina City IN RE: PETITION FOR THE DISSOLUTION AND/OR CANCELLATION OF MARRIAGE OF RAMONETTE TRINIDAD BURGOS AND LORNA PAULETTE EDURIA BURGOS FROM THE RECORD OF PHILIPPINE STATISTICS AUTHORITY (PSA) RAMONETTE TRINIDAD BURGOS, xX SP. PROC. CASE NO. 2023-1258-MK FORMAL OFFER OF EVIDENCE Petitioner through counsel and to this Honorable Court, most respectfully offers the following documentary exhibits, to wit: EXHIBITS DESCRIPTION PURPOSES Exhibit “A” | Consulate General of 1. To prove the authority of the Republic of the Atty. Jimmy Lacebal as the Philippines- the Attorney-in-fact of the |“A-1” Acknowledgment petitioner in the instant | (SPA); case; “A-2” Barangay Certification 2.To comply with the dated March 27, 2023; requirements of our procedural law; “A-3” Integrated Bar of the 3. To prove that Atty. Lacebal Philippines is a member of the “A-4” Identification Card of Integrated Bar of the Atty. Jimmy Lacebal; Philippines; Sworn Certification of 4. To prove that Atty. Lacebal Legal Consultant; was a resident of 102-A BMRC, Banahaw St., | Google printout; Highway Hills, Mandaluyong | City in compliance with Sec. | Exhibit “B” | Certificate of Live Birth 1. es Z of Ramonette T. Burgos petitioner Ramonette T.Page -2- Priscilla G. Trinidad. Burgos and that he was born on August 31, 1961 to Spouses Jose L. Burgos and | | Exhibit “C” Certificate of | Naturalization No. 43617666 “1 . To prove that the petitioner was a naturalized American Citizen on September 15, 2022 before the filing of the instant petition for the dissolution and/or cancellation of the marriage between Ramonette T. Burgos and Lorna Paulette E, Burgos from the record of the PSA. | Exhibit “D” Marriage Certificate issued by the Philippine Statistics Authority my . To prove that the petitioner and respondent —_ Lorna Paulette E£. Burgos were married on June 17, 1995, in Marikina City. | Exhibit "E” | Decree of Divorce . N . To prove that the Decree of . To prove the genuineness . TO prove also that the Divorce between the petitioner and the respondent was issued on September 28, 2012 by the District County of Nevada restoring them to the status of an unmarried person. and due execution of the said Divorce Decree. petitioner and the respondent were _ still Filipino citizens at the time of the divorce decree was issued which divorce decree is legally and validly binding between them and for said reason, petitioner seeks the | indulgence of the Honorable | Court to liberally interpret the substantive and) procedural laws in the) Philippines relative to such incident for the simplePage -3- reason that after the petitioner and the respondent has acquired the decision in the divorce decree, several years after they acquired an American citizenship through naturalization. The respondent having acquired her American citizenship few years before the petitioner receives his American citizenship through naturalization, henceforth, they both lost their Filipino citizenship. To prove that the present petition filed is in line with the ruling of the Supreme Court in the case of Corpuz | versus Santo Tomas! which held that, "the recognition of the foreign divorce decree may be made in a Rule 108 proceeding itself, as the object of special) proceedings (such as that in Rule 108 of the Rules of| Court) is precisely to establish the status or right! of a party or a particular) fact. Exhibit“F” | Justia - 2005 Nevada Revised Statutes (Apostilled) » . To prove that the petitioner | and the respondents were | governed by the Nevada! Revised Statutes 2005 and | therefore they have had acquired the Divorce Decree through a valid statute that is recognized in Nevada where they have been residing from the time the decree was obtained up to the present. 1G.R, No, 186571 dated August 11, 2010Page -4- 2. To prove further that said statute is considered valid and recognizable in our _ _ jurisprudence. Exhibit"G” | Judicial Affidavit 1. To prove all the allegations in the petition in support of the petitioner's claim for} recognition and/or cancellation of marriage between the petitioner and | respondent from the =| : records of the PSA. Exhibit “H” | Petition 1. To prove that the petitioner filed the instant petition for him to be granted its petition for the cancellation | of his marriage with the respondent from the | records of the PSA. = Exhibit “I” Order 1. To prove compliance with the jurisdictional | _ requirements. _ Exhibit “J” Return Registry Receipt 1. All to prove compliance with from Marikina Local the jurisdictional Civil Registrar requirements. Return Registry Receipt | from Office of the City Prosecutor Marikina Return Registry Receipt from Office of the Solicitor General Return Registry Receipt from Philippine Statistics Authority a Exhibit “K” | FilNews Publication 1. To prove compliance with May 23-28, 2023 the jurisdictional requirements of the Court “K-1" Page 3 of Exhibit “K” that the Order be published in a newspaper of general ("K-2" Newspaper Publication circulation in the May 28-June 4, 2023 Philippines, for three “K-3”” Page 3 of Exhibit “K-2” consecutive weeks.Page -5- aK4" "KS" Newspaper Publication June 5-11, 2023 Page 3 of Exhibit “K-4” Exhibit “L” Affidavit of Publication 1. To prove that indeed the Order was duly published. PRAYER WHEREFORE, it is respectfully prayed of this Honorable Court that the foregoing documentary exhibits, together with the testimony of Atty. Jimmy Lacebal, be admitted in evidence. After due admission in evidence of the foregoing documentary exhibits, as well as the testimony of Atty. Jimmy Lacebal, petitioner respectfully rests his case. Mandaluyong City for Marikina City, Metro Manila. This 8" day of May, 2024. LACEBAL DE RAMOS & BONGHANOY LAW OFFICES. Counsel for the Petitioner Unit 107-E BMRC, Banahaw Street, Highway Hills, Mandaluyong City Tel. No, 7621-9918 bi hi Y D. LACEBAL RN No. 02023/12-18-00 PTR No. 5425458/1-2-24/Mand. City Roll No. 30665 MCLE Compliance No. VII-0018451 Valid till 4/14/25 ~ SE Bina) fh Mah fap ATTY. VIVIAN V. VILLALON-LAPUZ Attorney Roll No. 42219 PTR No. 10074274/ 01-02-2024/ Makati City IBP No. 375940/ 12-27-2023/ Manila IV MCLE Compliance No.VII-0007607/October 16, 2021 Email address: [email protected] Mobile No. 09189242265Page -6- Copy furnished: OFFICE OF THE CITY PROSECUTOR 2F New Hall of Justice Bldg. Sta. Elena, Marikina City CERTIFICATION/ EXPLANATION Under Section 11, Rule 13 of the 1997 Rules of Civil Procedure That a copy of this pleading was sent to the Office of the City Prosecutor by LBC Private Courier and not by personal service as required by law, due to distance and lack of personnel to deliver the same personally.EBS, EXPRESS, Zi cowren oe ‘Ml Itoner's. Cony i ): gs seme 9s one, ae SRG TE RS EGG RESTOR, TRIAL REGIONAL, TRIAL COURT taro oyu BW OFAC or onic amnw Sr icy adress BRANCH 366 MARTKINA CITY MEM IL, OF FASS"E; Nar paon.ovouc Marion cHPETAL” USTICE’ sara ELENA CITY Or MIKI WATEONA, FeetOn ZaPrin. ReCION CCR) Bontooe Nee. s22e732,reasaorst13 EEntact wo guooveene SIR Bee ivaes nat Courier N-Pouch Regular | suas Ibcexpress.com 3: | raik to oor care Representative 98:27] tet. (632) 8858-5999 crt 1-800-10-8585-999 Lot us know of your experience: 3 bit .1y/CSATPR "Bact Mian comren ae. ii lle:= as seres sa wore Taw oeeerl ES BORG OTE TET THE, CITY PROSECUTOR Adress. 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