REPUBLIC OF THE PHILIPPINES

National Capital Judicial Region

REGIONAL TRIAL COURT

Branch No. 89

GINA LAO-TSOI CIVIL CASE NO.________________

Plaintiff,

--versus— For: Declaration of Nullity of Marriage

under Article 36 of the Family Code
CHI MING TSOI

Defendant

The testimony of the witness Dr. Sergie I. Alteza is being offered to prove that the defendant Chi Ming Tsoi is
impotent and not capable of erection.

JUDICIAL AFFIDAVIT

I, Gina Lao-Tsoi, of legal age, married, Filipino citizen and with residence at 815 Jutz Residences, Josefina
Street, Sampaloc, Manila, after having been duly sworn to in accordance with law, hereby depose and state
that:

I am the wife of the defendant—Chi Ming Tsoi. We were married at the Manila Cathedral, Intramuros, Manila
evidenced by a marriage contract (Exh. “A”) attached herewith.

In relation to the above-entitled case, the prosecuting counsel, Atty. Joel Mendoza with address at
__________________asked me questions which questions I answered while I was in his law office, fully
conscious that I did so under oath and that I may face perjury and any other criminal liability for false
testimony.

The questions asked by Atty. Joel Mendoza and the answers I gave are as follows, to wit:

1. QUESTION (Q): Please state your name, age, residence, and occupation.
ANSWER (A): I am Gina Lao-Tsoi, 24 years old, living in 815 Jutz Residences, Josefina Street,
Sampaloc, Manila and is self-employed.
2. Q: What brought you here?
A: To give a sworn statement by way of a judicial affidavit, in the above-captioned civil case.
3. Q: Do you undertake to answer the questions asked of you, fully conscious that you will do so under
oath, and that you may face criminal liability for false testimony or perjury?
A: Yes.
4. Q: Do you know the defendant in this case?
A: Yes, Sir.
5. Q: How are you related to the defendant in this case?
A: He is my husband.
6. Q: What is the purpose of your testimony?
A: To prove to the court that me and my husband have not cohabitated since the celebration of our
marriage.
7. Q: From the celebration of your marriage up to the present, did you and Mr. Chi Ming Tsoi engaged in
any sexual congress of any kind?
 A: Never, Sir. Not even once.

8. Q: Mrs. Gina Lao-Tsoi, personally, what is the significance of consummating your marriage?
A: Sir, it would have affirmed the affection of the mutual bond we have for each other which he has
proven otherwise.
9. Q: Is there an instance in your marriage where you felt inadequate for failure to have sexual congress
with your husband--Mr. Chi Ming Tsoi?
A: Yes. Sir.
10. Q: What instances were these?
A: It happened twice. The first instance happened during our honeymoon night right after the
celebration of our marriage in Manila Cathedral. We went subsequently to a separate room in my
mother-in-law’s house. We slept in the same bed only to find his back turned against me.
11. Q: During this first instance, no sexual activity happened all through the night?
A: None, Sir. Not even once.
12. Q: So Mrs. Gina Lao-Tsoi, when did the second instance happen?
A: To materialize my intent to have sexual intercourse with my husband, we held our second
honeymoon in Baguio City. Surprisingly, he brought 4 people (my mother, an uncle, her mother, a
nephew) along with us. During our honeymoon nights, he would fall asleep in the rocking chair instead
of sleeping beside me.
13. Q: I have no other further any questions, do you have anything to modify or retract, Madam Witness?
A: Yes, Sir.
14. Q: Are you willing to sign this statement?
A: Yes, Sir.

Affiant further sayeth naught.

 ______________________

AFFIANT

SUBSCRIBED AND SWORN TO BEFORE ME, a notary public in Quezon City on________________. Affiant
personally came and appeared to with her TIN ID No. 75846389 issued by the Bureau of Internal Revenue on
____________, bearing her photograph and signature and Passport No. 018725624 issued by the Department
of Foreign Affairs on _____________ 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.

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. 5;
Page No. 23;
Book No. VI;
Series of ____
 ATTESTATION
I, Atty. Joel Mendoza, of legal age, Filipino, with postal address at ___________________ after being duly
sworn depose and say that:

 I conducted the examination of Dr. Sergie I Alteza for Civil Case No.____________entitled GINA-LAO
TSOI vs CHI MING TSOI at my law office in ______________;
 I have faithfully recorded the questions I asked and the corresponding answers that the witness gave;
 Neither I nor any other person then present coached the witness regarding her answers;

IN WITNESS WHEREOF, I have hereunto set my hand this ______ day of ______at Quezon City.

ATTY. JOEL MENDOZA

SUBSCRIBED AND SWORN TO BEFORE ME, a notary public in Quezon City on ____________. Affiant
personally came and appeared to with IBP ID No. 178690 issued by the Integrated Bar of the Philippines on
_______________, bearing his photograph and signature and Passport No. 1673262 issued by the
Department of Foreign Affairs on _____________, 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.

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. 13;

Page No. 2;
Book No. VI;
Series of ______.

Copy Furnished:

Atty. Anthony Jhonuel A. Elica

Counsel for Defense

___________________
___________________

EXPLANATION

A copy of this Judicial Affidavit is served on the Court, the Counsel for the Defendant Chi Ming Tsoi, via
LBC Express Corp./registered mail due to the great distances of their respective addresses, due to the urgency
of filing the same, and due to the lack of field personnel of the undersigned counsel at this time.

Atty. Joel Mendoza