Pre-Trial Brief
Pre-Trial Brief
PRE-TRIAL BRIEF
Petitioner, through the undersigned counsel and unto this Honorable
Court, respectfully avers that:
I.1 This case is a petition to impugn the legitimacy of Ma. Sofia Louis
Mercado Castro as the legitimate daughter of Ronald Castro.
Petitioner prays to this Honorable Court that the Local Civil
Registry to cancel Registry No. 2013 08748 and issue a New Birth
Certificate.
II.1 Petitioner and Respondent got married on June 15, 2007 at Regional
Trial Court Branch 37, Calamba City, Laguna;
II.4 On the same year, respondent gave birth to their legitimate child
while petitioner is in Canada but Petitioner did not witness such
event;
II.6 From 2010 until 2022, Petitioner constantly gave support to his
family. He has constant communication with her daughter and
respondent thru video calls or chats;
II.7 On June 17, 2022, Petitioner returned to the Philippines but did not
informed Respondent;
II.8 Upon arrival, petitioner went straight to their house from the airport.
When petitioner arrived in their house, he noticed that another child
is living in their home but respondent told him that it was her niece;
II.9 Petitioner asked Respondent to return the alleged niece to her
parents but the latter refused to return. Such refusal on the part of
the respondent sparked arguments and fights which lead to the
petitioner leaving their conjugal dwelling;
II.10 Petitioner talked to his brother Roderick Castro regarding the
situation of his family. Petitioner also told his brother that a certain
child is living in their home. Roderick told petitioner that he is
doubtful regarding the alleged status of the child being niece of
Respondent;
II.11 Roderick Castro made an investigation thru social media
about the identity of the child. He found out that the name of the
child is Ma. Sofia Louis Castro;
VI. WITNESS
The Petitioner reserves the right to present additional witnesses during the
course of the proceedings upon meritorious reasons.
VII. EVIDENCE
PRAYER
Other reliefs and equitable under the premises are likewise prayed for.
Copy Furnished:
EXPLANATION
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