JUDICIAL AFFIDAVIT OF MRS.

XIANG TSOI
(IN QUESTION AND ANSWER FORM)

I, Xiang Tsoi, Filipino citizen, married and resident of #1, Banawe St.,
Brgy Maharlika, La Loma, Quezon City, Metro Manila, and in response to
the questions propounded by Atty. Anthony Jhonuel Elica with office
address at 22F ACCRALAW Tower, 2nd Ave. cor. 30th St., Crescent Park
West, Bonifacio Global City, 0399 Taguig, Metro Manila, hereby depose and
state:1

I. Preliminary Matters

1. Q) Please state your name and personal circumstances.

A) I am Xiang Tsoi Filipino Citizen, of legal age, married, with home

address at #1, Banawe St., Brgy Maharlika, La Loma, Quezon
City, Metro Manila.

2. Q) What is your educational background?

A) I am a college graduate.

3. Q) What is your current profession?

A) I am a businesswoman.

4. Q) Do you know Mrs. Gina Lao-Tsoi?

A) Yes, she is my daughter-in-law.

5. Q) To whom Mrs. Gina Lao-Tsoi married?

A) She is married to my son, Chi Ming Tsoi.

6. Q) How long have they been married?

A) They have been married since 22 May 1988.

7. Q) Where was the wedding ceremony held?

A) The wedding ceremony and the reception were held at South Villa,
Makati.

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This Judicial Affidavit was taken at the office of Atty. Anthony Jhonuel Elica at 22F ACCRALAW
Tower, 2nd Ave. cor. 30th St., Crescent Park West, Bonifacio Global City, 0399 Taguig, Metro Manila.

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8. Q) After the wedding, where did the Mr. Chi Ming Tsoi and Mrs. Gina
Lao-Tsoi stay?

A) They went to my house at Quezon City.

9. Q) And what did they do when they were in your house?

A) They slept together in one of the bedrooms in my house.

10.Q) Other than your house, where did the couple go to celebrate their
honeymoon after their wedding?

A) My son invited us to go with them to Baguio together my brother

and my nephew. We stayed in Baguio for 4 days.

11.Q) How was your relationship with Mrs. Gina Lao-Tsoi?

A) We have a good relationship; I even gave her some of my

jewelries.

12.Let’s now move forward, based on your knowledge with the

relationship of Mr. Chi Ming Tsoi and Mrs. Gina Lao-Tsoi, what is the
current situation of the couple?

A) According to my son, they are no longer living together since 15

March 1989. My son told me that Gina is no longer happy with his
marriage with my son.

13.Q) Did Mr. Chi Ming Tsoi tell you how he responded to these alleged
behavior of his wife?

A) My son said that at first he tried to tolerate her for the sake of their
marriage. That despite of their separation, their marriage will
remain valid because they are still very young and there is still a
chance to overcome their differences. However, he said Gina said
she could not bear living under the same roof with my son and so
she left him.

14.Q) What did you think was the cause of their misunderstandings?

A) It is because Gina is accusing my Son of being gay.

15. Q) You mentioned that Mrs. Gina Lao-Tsoi accused your son of being
gay, is there any instances to which may lead that Ms. Chi Ming Tsoi
gay?

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 A) No, I cannot recall of any.

16.Q) Other than the accusation of Mrs. Gina Lao-Tsoi that Mr. Chi Ming
Tsoi is gay, what are other causes of the differences between the
couple?

A) Gina is also accusing my son that he only married her for purposes
of maintaining my son’s Filipino residency.

17.Q) How did Mr. Chi Ming Tsoi reacts to these accusations?

A) My son denies all of these and despite of these accusations, my son

does not want their marriage annulled because my son loves Gina.

I warrant that the exhibits attached to this affidavit are faithful

reproductions of the original.

I declared under the penalties of perjury that the answers to the

foregoing questions, made under oath, are made in good faith, verified by
me, and to the best of my knowledge and belief, are true and correct.

IN WITNESS WHEREOF, I have hereunto set my hand this _th

day of ______ ____ at Makati City.

XIANG
TSOI
Affiant

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 SUBSCRIBED AND SWORN to before me, a notary public in and
for Makati City this __th day of ____ ____. Affiant personally came and
appeared with her Philippine Passport with no. 081181 issued by the
Department of Foreign Affairs on __th day of ___ ____ bearing her
photograph and signature, known to me as the same person who personally
signed the foregoing instrument before me and avowed under penalty of law
to the whole truth of the contents of said instrument.

Atty. Joaquin T. Regalado

Notary Public for Quezon City
Unit 8s, Catalina Building, East Ave, Quezon City
Appointment No. 9021 until December 31, 20__
IBP No. 123456; 4/12/__- Quezon City
Roll No. 47378 10/08/93
MCLE No. I 087968; 8/10/__
MCLE No. II 003867; 3/14/__

Doc No. 11;

Page No. 11;
Book No. 11;
Series of 2018.

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 ATTESTATION

I, Anthony Jhonuel Elica, of legal age, Filipino, with office address

22F ACCRALAW Tower, 2nd Ave. cor. 30th St., Crescent Park West,
Bonifacio Global City, 0399 Taguig, Metro Manila hereby depose and state
that:

1. I personally conducted the foregoing examination of Mrs.

Xiang Tsoi at 22F ACCRALAW Tower, 2 nd Ave. cor. 30th St.,
Crescent Park West, Bonifacio Global City, 0399 Taguig, Metro
Manila;

2. I certify that I faithfully recorded the questions I asked and the

answers of the witness; and

3. I certify that no one coached Mrs. Tsoi regarding the answers to

the questions propounded.

IN WITNESS WHEREOF, I have hereunto set my hand this __th

day of ____ _____ at Quezon City.

ANTHONY JHONUEL ELICA

Affiant

SUBSCRIBED AND SWORN to before me, a notary public in

and for Makati City this __th day of ____ ____. Affiant personally came and
appeared with her Philippine Passport with no. 081181 issued by the
Department of Foreign Affairs on __th day of ___ ____ bearing her
photograph and signature, known to me as the same person who personally
signed the foregoing instrument before me and avowed under penalty of law
to the whole truth of the contents of said instrument.

Atty. Joaquin T. Regalado

Notary Public for Quezon City
Unit 8s, Catalina Building, East Ave, Quezon City
Appointment No. 9021 until December 31, 20__
IBP No. 123456; 4/12/__- Quezon City
Roll No. 47378 10/08/93
MCLE No. I 087968; 8/10/__
MCLE No. II 003867; 3/14/__

Doc No. 12;

Page No. 15;

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Book No. 11;
Series of 2015.

Copy Furnished:

Atty. Joel Mendoza

Counsel for Defense

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