Objections 9.1.18

9.01.
18
OBJECTIONS TO THE JUDICIAL AFFIDAVIT OF EUGENE LEE
1) In Answer to Question No. 8, all statements after the word “Yes” should be deleted inasmuch
as the question is only answerable by a yes or no answer and does not ask for any explanation or
expounding. There should be another independent question as the witness just volunteered an
answer sans any proper question. Thus, it is objectionable and should be stricken off from the
record.
2) In Q9, If the preceding answer (A8) has been stricken

out, Q9 should likewise be stricken out for lack of proper
foundation or lack of basis and it assumes facts not in evidence (AFNIE), the question is linked
to the deleted answer in A8. Q9 is a question that contains information not yet in record. Since
the question is linked to the preceding answer w/c was stricken out, the prerequisite fact has not
been entered to make the succeeding question of fact admissible.
3) In Answer to Question No. 10, this is objectionable, the same as in Q9. For lack of proper
foundation or lack of basis and it assumes facts not in evidence, the question is linked to the
deleted answers in A8 and A9, a question that contains information not yet in record. Since the
question is linked to the preceding answers w/c were stricken out, the prerequisite fact has not
been entered that would make the succeeding question of fact admissible. Note: If allowed, all
statements after the word “Yes” should be deleted inasmuch as the question is only answerable
by a yes or no answer and does not ask for any explanation or expounding. There should be
another question before the next statements.
4) Question No. 11, the answer after the word No should be deleted for not being responsive.
The question is answerable by yes or no. There should be another independent question. Note:
Assuming the question will be allowed to retain, all statements in the Answer after the word
“No” should be deleted inasmuch as the question is only answerable by a yes or no answer and
does not ask for any explanation or expounding.
5) Q12 should be stricken out for LPF/ LB and it assumes facts not in evidence (AFNIE), the
question is linked to the deleted answer in A11, It is a question that contains information not yet
in record. Since the question is linked to the preceding answer w/c was stricken out, the
prerequisite fact has not been entered that would make the succeeding question of fact
admissible.
6) Q13 should be stricken out for LPF/LB, the question is linked to the deleted answer in
A12. Note: AFNIE
7)Q 14 should be stricken out for LPF/LB, the question is linked to the deleted answer in A13.
AFNIE
8) Q 15 should be stricken out for LPF/LB, the question is likewise linked to the deleted answer
in A13. Note: AFNIE
9) Q16 should be stricken out for LPF/LB, the question is linked to the deleted answer in A15.
Note: AFNIE. Second sentence of Answer No. 16 should be deleted for being hearsay or not
based on personal knowledge inasmuch as the facts being testified to are matters when the
witness has already left for work. (If you know-)
Q17 should be stricken out for LPF/LB, the question is linked to the deleted answer in A16.
10)
AFNIE
Q18 should be stricken out for LPF/LB, the question is also linked to the deleted answer in
11)
A13. AFNIE
12)Q19 is “as a parent” how do you instill discipline on Patrick, the answer is not responsive,
witness answered WE never used physical forms ... he volunteered to include his wife without
any proper question. LPF/LB/AFNIE
13) Q20 is “What kind of proper values and manners DO YOU TEACH PATRICK? answer is
not responsive, witness answered is not responsive “We teach him the value of honesty ...” here,
he again volunteered to include his wife without any proper question, there shd be another
question independent thereof. AFNIE/LB
14)Q21 should be stricken out for LPF/LB, the question is also linked to the deleted answer in
A20. AFNIE
15)
A21. AFNIE
16)Q22,23,24 & 25 shd be stricken out for LPF/LB, the questions are also linked to the deleted
answer in A21. AFNIE
17)
A21. AFNIE
A26. AFNIE
A27. If allowed, ...... AFNIE.
20) Q29.....If allowed…. AFNIE
21)Q30 Statement after a Yes answer should be deleted, there should be another question
independent thereof,
22) Q31 is vague and unintelligible question, “What happened” without any connecting words is
not even a complete thought of a sentence. AFNIE
A31. AFNIE
A32 . AFNIE
A28 . AFNIE
26) If all the Q n A are deleted, “ Q35 Shd be stricken out for LPF/ LB/ AFNIE. Was Patrick
ever reprimanded in school for committing bullying acts against Bryce? If allowed, the answer
after the word No shd be deleted ( Patrick was never reprimanded.... against anyone...) for being
volunteered answer sans any proper question independent of the preceding question.
27)Q36 shd be stricken out for LPF/LB, the question is also linked to the deleted answer in A35
. AFNIE
28) Q37 shd be stricken out for LPF/LB, the question is also linked to the deleted answer in A36
. AFNIE
29) Q38 shd be stricken out for LPF/LB, the question is also linked to the deleted answer. Again,
in A36. AFNIE
and A38. AFNIE
Q40 shd be stricken out for LPF/LB, the question is also linked to the deleted answer in 39.
31)
AFNIE
Q41 shd be stricken out for LPF/LB, the question is also linked to the deleted answer in A40.
32)
AFNIE
Q42 shd be stricken out for LPF/LB, the question is also linked to the deleted answer in A41 .
33)
AFNIE
. AFNIE
35) Q43 ---LPF/LB/AFNIE also the question is What did YOU do then, if any, after hearing
these... the answer is not responsive, he answered We as he volunteered to include his wife while
it was only him that is being asked what did he do after the meeting. There shd be another
independent question like what abt ur wife what did she do.... but there was none.( In fact, during
the said meeting his wife was silent at all and did not even say a word.) It is improper for the
witness to answer for another person on his direct testimony any person who is not before this
court to appear, testify and take an oath.
36) Q44 shd be stricken out for LPF/LB/AFNIE the question is also linked to the deleted answer
in A43 .
in A44.
in A45.
in A46.
in A47
in A48
in A45
43) Q51 shd be stricken off for LPF/LB/AFNIE this is linked to A50 because this question has
not proper foundation as a result of deleted preceding questions .
in A51.
in A52.
46) Q54 shd be stricken out for LPF/LB/AFNIE the question is also linked to the deleted
preceding answers in A50, A51 & A52.
47) Q55 shd be stricken out for LPF/LB/AFNIE the question is also linked to the deleted answers
in A50.
in A50 & succeeding questions that have been stricken off also the question is improper, How
did M. Go destroy your reputation as Patrick’s parents. The question is directed to the witness
and his wife while her wife is not presented to the court to testify. Objectionable bec the witness
volunteered to include in his answer his wife who was not presented in court to testify and to
take an oath.
in A56.
in A56.
in 58.
in A58 & A59
in A54. The question is improper as it assumes ..... mental anguish to all of you...” ( expound ) 5)
Third sentence of Answer No. 20 should be deleted for being unresponsive to the question.
Witness cannot for another person who is not present in court to testify and take her oath.
54) Q62 is linked to A55, 63 to 62, 64 linked to A50.
CROSS-EXAMINATION QUESTIONS ON EUGENE LEE
Caution: Put a cross to the deleted answers and not to ask question thereof
Objective I: To establish lack of time with Patrick Eugene
If Q and A from 8-17 will be allowed by the court.
1) In your Answer to the preliminary question of your JA, you said that you’re working as Senior
Director of a Shared Service Center for a major multi-national company. In layman’s term is
Shared Service Center the same as business process outsourcing (BPO) while the call center is just
one sector of the BPO, am I right?
Based on your testimony it appears that your work schedule starts in the evening and you go home
in the morning the next day, correct?
By the way, what is your work schedule during those times when Patrick was in Grade 2 at St Jude
and until the time you have executed your JA in February 2014?
Since you are a Senior Director your work requires you to be there for at least eight (or twelve)
hours, is that correct?
In your JA you said that (Answer to Question No. 16) that, “After dinner, I leave for work.” So,
you usually leave for work at about 6PM, am I right?
And during that time your family lived in Caloocan City while your workplace is located in
Muntinlupa, correct?
From Caloocan City (P Jacinto St) to Muntinlupa it would take you more than an hour or about 2
hours travel time, am I correct?
And you still have to travel for more than an hour or (two hours) from home to your workplace
but shorter hour in going home early morning the next day, is that right?
(In your Answer to Question No. 17) You also claimed that you “get home from work early
morning the next day.” So, taking into account your 8 (or 12) hour work schedule and travel time,
you get home at about 6:00AM (or 9AM) in the morning of the next day, am I correct?
While Patrick school schedule when he was Grade 2 in SJCS is from 7:15AM to 4:15PM correct?
And Patrick was a school bus rider, correct?
And this is the yellow big school bus of 50 seater of St Jude that could accommodate about 100
students in a trip?
Patrick has to leave home for school past 6AM because there are a lot of students to be picked up
from Caloocan to Manila where St Jude is located, is that right?
And it would take him more than an hour or two hours of traveling from home to school, vice
versa because he was riding a school bus, is that right?
And since you are working at night, am I correct to say that after coming from work you
immediately take your sleep?
In your Answer to Question No. 14, you said that “when Patrick wakes up in the morning, Joanne
has breakfast with him” and this is a routine. Am I correct to say that you do not routinely take
breakfast with them because you are either still at work or still sleeping by that time they take
breakfast?
In other words, your statements in Answer No. 14 are not based on your personal knowledge
because you are either still at work or sleeping by that time your son Patrick Eugene wakes up and
until he leaves for school, am I correct?
Your time with Patrick routinely starts only “when Patrick gets home from school” as stated in
Answer No. 15 of your JA, is that correct?
And when Patrick was in Grade2 he would able to get home from school past 6PM ?
While you have to leave for work at about6PM?
Also during that time when Patrick was in Grade 2 you mentioned your wife was working as Asst
Bank Manager in a bank, is that right?
Since she was holding a managerial position, she also works more than 8 hours a day, am I right?
Taking into account the travel time your wife usually arrives home from work past 7PM or 8PM,
is that right?
In other words, you routinely spend about an hour only with your son Patrick during weekdays?
With that short hour you could not possibly supervise his activities when he arrives home from
school, is that right?
Objective II: To establish that he is neglect or remiss in supervising the activities of Patrick Eugene
at home
Do you have a computer or laptop at home?
Does Patrick Eugene Lee have access to this computer or laptop?
Can he operate and use this computer or laptop alone?
Do you know if Patrick Eugene has a Facebook account at the time when he was in Grade II?
(Follow up: If yes, are you aware of the language of Patrick Eugene in his conversations using his
FB account?
If no, is it correct to say that you did not monitor the conversation of Patrick Eugene Lee with
other persons using online media such as FB?)
I will show you the conversation log print outs of one Patrick Eugene Lee in the FB account, for
identification. These print outs were stricken out but already tendered or proffered during the time
plaintiff was presented to the stand on a mere ground of relevancy because according to the court
the conversations did not involve Bryce but their other classmates that’s why they were irrelevant.
However, we intend to present these again during the rebuttal. And I will confront the witness to
ascertain the truthfulness of his testimony now. As shown by these screen shots, would you tell us
if this is the picture of your son Patrick?
Would you agree with me that your complete home address in your JA and the address posted in
Patrick FB account is the same? Is that right?
Are you are aware of this conversation? (Confront with screenshots)
21) You said in your Answer No. 19 of your JA that you “spend time to explain to him clearly
what is right and what is wrong and the consequences when he does not do what is right”. Did you
explain to Patrick the right way to converse in his FB account?
In the conversation posted on Patrick FB did you supervise him when he posted ______
What about his post that _______, did you supervise Patrick on this?
Did you not bother to delete those posts upon learning of its existence? Or you were not totally
aware of those bec you didn’t supervise him at all in his social media usage?
Were you aware that his FB account was in public setting, so that anyone who has a Facebook
account can see his posts?
Would you agree with me that Patrick’s safety and your family security is primordial to you
concern, is that right?
But do you also agree with me that when Patrick posted your complete address in this FB account
he put the family privacy and security at a risk?
22) Do you have a phone at home?
23) Does Patrick Eugene have access to this phone?
24) Can he use and make calls with this phone?
25) How do you explain to Patrick Eugene the right way to converse with others over the phone?
26) Have you heard Patrick Eugene converse with Bryce Wayne Go over the phone?
27) Have you heard Patrick Eugene utter foul or cuss words to Bryce Wayne Go over the phone?
(Follow up: If yes, what did you do? If no, is it correct to say that you did not monitor or supervise
the conversation of Patrick Eugene Lee with other persons over the phone?)
Objective III: To establish that his version of the complained acts and of the March 8, 2011 incident
is contrary to the factual findings of the school
Are you aware that aside from you and your wife, St Jude and its four school personnel were also
defendants in the instant case?
Did you read the Complaint in the instant case?

Did you also read you and your wife Answer to the Complaint?
Did you also read the Answer of St Jude in this case?
What about the Answer of Nicasio, de Lara, Iglesia and De Guzman were you able to read their
Answer to the Complaint?
You mentioned in your JA that Patrick version of the story is consistent with the version of the
school personnel, is that right?
When you said school personnel you referred to your co- defendants in the instant case, right?
In the Answer of defendant St Jude it stated that.....
In the Answer of the school personnel it stated that.....
Therefore your versions of the incident were inconsistent to their version and not the way you
claimed it to be, isn’t it?
28) In your Answer to Question No. 29, you stated that “Patrick would never forcibly take, through
threat or intimidation, Bryce’s money and personal things or that of other St. Jude students” and
in your Answer to Question No. 34, you stated that “Patrick would never commit bullying acts to
Bryce or to other St. Jude students for that matter”.
Would you agree that the taking of money and personal things and the bullying acts of Patrick
Eugene on Bryce was investigated by the school, thru its Prefect of Discipline? Better to confront
the letters of the charge sheet
29) Also, in your Answer to Question No. 38, you stated the version of Patrick Eugene Lee about
the March 8, 2011 incident is that “while they were playing wrestling, Bryce tried to toss Patrick
over by slinging Patrick’s arm over his shoulder.” Would you agree with me that this March 8,
2011 incident was also investigated by the school, thru its Prefect of Discipline?
30) In fact, the Prefect of Discipline of Saint Jude has formally charged, thru a charge sheet, Patrick
Eugene after he conducted an investigation about the complained acts and the March 8, 2011
incident against you son, is that correct?
31) And this charge sheet was in fact served upon you by the Prefect of Discipline, Mr. Anthony
de Lara, which stated the acts committed by you son which he had threshed out after he conducted
an investigation, is that correct?
32) I am showing to you a copy of the charge sheet attached to the Answer of defendants Nicasio,
et. al., do you confirm that this is the charge sheet served upon you by the Prefect of Discipline,
Mr. Anthony de Lara?
33) What did you tell Patrick Eugene after you received the charge sheet? better yes or no question
34) Patrick Eugene submitted his written explanation to this charge sheet, is that correct?
35) You assisted and guided Patrick Eugene in preparing and submitting his written explanation
to the charge sheet, is that correct?
36) I am showing to you a copy of the written explanation of Patrick Eugene to the charge sheet,
bearing his, yours, and your spouse’s signatures, and this which was attached to the Answer of
your co-defendants, do you confirm that this is the written explanation that Patrick Eugene,
assisted by you and your wife Joanne, has executed and submitted to the Prefect of Discipline of
Saint Jude?
37) After you submitted your written explanation, you mentioned that the school meted the penalty
of Conduct C and probation on Patrick Eugene, do you confirm this?
And this penatly was reduced into writing in a Decision rendered by the school, is that correct?
And you were given a copy of the said decision?
In gist, in the said decision the school resolved that it did not give credence to the written
explanation submitted by Patrick which you and your wife assisted, is that correct?
Therefore he was found liable to the charges against him, do you confirm this?
Also in the said Decision, ________, is that correct?
You have totally forgotten the content of the said Decision?
Was isn’t important to you to recall the contents of the said Decision?
38) Now, you mentioned that Patrick did not took the money and personal things of Bryce, that
Patrick did not commit bullying acts on Bryce, and that Patrick did not physically hurt Bryce on
March 8, 2011;
Did you move for a reconsideration of the decision of the school which imposed a penalty of
Conduct C and probation on Patrick Eugene?
39) And despite the decision of the school imposing the penalty of Conduct C and probation on
Patrick Eugene, you also did not interpose an appeal to higher authorities?
40) In the light of the decision of the school imposing upon Patrick Eugene the penalty of Conduct
C and probation, do you still maintain your stand that Patrick Eugene did not took the money and
personal things of Bryce?
41) Do you also still maintain that Patrick Eugene did not commit bullying acts on Bryce despite
the decision of the school imposing the penalty of Conduct C and probation on your son?
42) Do you also still maintain that Patrick Eugene did not physically hurt Bryce on March 8, 2011
despite the decision of the school imposing the penalty of Conduct C and probation on your son?
43) Do you have a copy of the decision of the school? (Follow up: If yes, could you produce and
submit it in this court for our examination?)
Also in your JA, you did not even bother to attach the Charge Sheet and Patrick’s written
explanation, is that right?
Objective IV: To establish that he and the school did not impose sanctions on prior incident
wherein Patrick Eugene took and used the money of his classmate
44) In your Answer to Question 31, you narrated about an incident wherein Patrick Eugene asked
his classmate to buy him a book and this classmate ended up short on cash to purchase his own
book. How did you come to know about that incident?
45) You also said in your Answer to Question 32 that the school merely asked you to reimburse
the student for the cost of the book. So, is it correct to say that the school did not impose any
disciplinary action on Patrick Eugene for asking his classmate to buy him a book which resulted
in this classmate of him ending up short on cash to buy a book of his own?
46) In fact, the school did not issue any charge sheet against Patrick Eugene with respect to that
incident, is that correct?
47) As found by the school Prefect of Discipline, the action of Patrick Eugene in taking and using
the money of his classmate was committed again when he did it to Bryce and his classmates in
Grade II; did you just want to reimburse the other kids this time around?
In fact, in your written explanation you said that Patrick should ask from his parents for money,
rather than to be contented with his own allowance.
Objective V: To establish his own perception of how effective he guides and disciplines Patrick
Eugene in the light of the decision of the school
48) In your answer to Question No. 53, you said that you taught proper values and manners to
Patrick Eugene.
These values and manners you allegedly taught him did not suit well to Patrick’s FB posts like I
will kill Jetrix .....
49) You also stated that you showered him with enough love, attention, guidance and time. Would
you agree with me that your enough love, attention, guidance and time did not suit well in his FB
posts that....
50) When the school came up with the decision that Patrick Eugene was found guilty of committing
the acts charged upon him, do you still consider yourself not to have been remiss in your parental
duties to him? (Follow up: If yes, so you did not take new or additional steps to guide your son
Patrick Eugene? If no, that’s it!)
Objective VI: To disprove his counterclaim
51) In your Answer to Question No. 56, you stated that Atty. Go made it appear to St. Jude, its
administrators, teachers, staff, co-parents and other students that you and your wife are not good
parents, and that you even teach and encourage Patrick Eugene to do wrong to others through
bullying and forcibly taking others’ money and personal things, do you confirm that?
52) In you Answer to Question No. 57, you stated that Atty. Go repeatedly informed St. Jude, its
administrators, its administrators, teachers, staff, co-parents and other students that Patrick bullied
Bryce and has been forcibly taking money, do you confirm that?
53) When you say Atty. Go “made it appear” to them and that she “repeatedly informed” them,
what do you mean by that? (Follow up: Do you have personal knowledge? How?)
Did you see me campaigning?
Was it because I sent a formal letter of complaint to the school authorities that for you it was
campaigning?
Was it because I asked for the formal investigation of what happened to my son during the time
Bryce got physically, emotionally and mentally hurt in the school, was it campaigning to you?
You accused plaintiff of campaigning without a single proof to support of your claim, isn’t it?
You are an alumnus of St Jude, right?

Graduated in 1988?
Just like you, you want your son Patrick to graduate at St Jude, isn’t it?
54) Is it not a fact that the bullying and taking of others’ money and property committed by you
tson against Bryce and other students was investigated by the school, thru defendant Anthony de
Lara?
55) In fact, and as plaintiff only came to know when this case was already filed, you and your son
were given a chance to answer the charges against him the basis of which were threshed out after
defendant de Lara has conducted an investigation and interview with several students, is that right?
56) Thereafter, the school came up with a decision which meted the penalty of conduct C and
probation on your Patrick Eugene and you did not move for any reconsideration or interpose an
appeal, is that right?
57) Despite the decision of the school against your son, you still maintain that the charges of
bullying and taking of money committed by your son are false?
58) Do you usually insist on the version of your son even when the evidence and the investigation
findings are contrary to what he has told you?
59) Mister witness, do you consider yourself as having the primary duty to guide and discipline
Patrick Eugene not to bully others or not to take others’ money and property?
60) Now, you also mentioned that the incident and the filing of the case were even caused to be
published in a newspaper of general circulation, isn’t it?
61) Did you bother to check or verify with the publisher of that newspaper who caused the
publication?
62) Did you also bother to check with the publisher had Atty. Go had asked that the publication be
removed because it was done without her consent and it unduly provided information about her
personal circumstances particularly her residential address was shown and published in that
newspapers?
Did you notice that the publication was a brief and undetailed story of the instant complaint?
And you didn’t even bother to ask the publisher where did they get their source, isn’t it?
And without any effort on your part or any proof to substantiate your claim you would unjustly
accused that it was herein plaintiff who caused the said publication, isn’t it?
Are you aware that herein plaintiff’s claim for damages is about 1.2M in totality?
While you are demanding a total of 17M as your counterclaim, is that right?
Do you have a professional license issued in the Phils just like the plaintiff, a lawyer by profession?
How did you come up with the said 10M moral damages, where in fact it is your son who continued
to study at St Jude after the incident in 2011 while Bryce had to immediately leave the school?
What was your basis of your 5M claim for exemplary damages while_______....?
What was your basis of your 2M atty’s fees while you did not present supporting documents that
you have spent 2M by way of atty’s fees?
Is that the way you teach your child Patrick how to earn or get money from others?
9.01.18
OBJECTIONS TO THE JUDICIAL AFFIDAVIT OF EUGENE LEE
1) In Answer to Question No. 8, all statements after the word “Yes” should be deleted inasmuch
as the question is only answerable by a yes or no answer and does not ask for any explanation or
expounding. There should be another independent question as the witness just volunteered an
answer sans any proper question. Thus, it is objectionable and should be stricken off from the
record.
2) In Q9, If the preceding answer (A8) has been stricken

out, Q9 should likewise be stricken out for lack of proper
foundation or lack of basis and it assumes facts not in evidence (AFNIE), the question is linked
to the deleted answer in A8. Q9 is a question that contains information not yet in record. Since
the question is linked to the preceding answer w/c was stricken out, the prerequisite fact has not
been entered to make the succeeding question of fact admissible.
3) In Answer to Question No. 10, this is objectionable, the same as in Q9. For lack of proper
foundation or lack of basis and it assumes facts not in evidence, the question is linked to the
deleted answers in A8 and A9, a question that contains information not yet in record. Since the
question is linked to the preceding answers w/c were stricken out, the prerequisite fact has not
been entered that would make the succeeding question of fact admissible. Note: If allowed, all
statements after the word “Yes” should be deleted inasmuch as the question is only answerable
by a yes or no answer and does not ask for any explanation or expounding. There should be
another question before the next statements.
4) Question No. 11, the answer after the word No should be deleted for not being responsive.
The question is answerable by yes or no. There should be another independent question. Note:
Assuming the question will be allowed to retain, all statements in the Answer after the word
“No” should be deleted inasmuch as the question is only answerable by a yes or no answer and
does not ask for any explanation or expounding.
5) Q12 should be stricken out for LPF/ LB and it assumes facts not in evidence (AFNIE), the
question is linked to the deleted answer in A11, This is a question that contains information not
yet in record. Since the question is linked to the preceding answer w/c was stricken out, the
prerequisite fact has not been entered that would make the succeeding question of fact
admissible.
6) Q13 should be stricken out for LPF/LB, the question is linked to the deleted answer in
A12. Note: AFNIE
7)Q 14 should be stricken out for LPF/LB, the question is linked to the deleted answer in A13.
AFNIE
8) Q 15 should be stricken out for LPF/LB, the question is likewise linked to the deleted answer
in A13. Note: AFNIE
9) Q16 should be stricken out for LPF/LB, the question is linked to the deleted answer in A15.
Note: AFNIE. Second sentence of Answer No. 16 should be deleted for being hearsay or not
based on personal knowledge inasmuch as the facts being testified to are matters when the
witness has already left for work. (If you know-)
Q17 should be stricken out for LPF/LB, the question is linked to the deleted answer in A16.
10)
AFNIE
11)
A13. AFNIE
12)Q19 is “as a parent” how do you instill discipline on Patrick, the answer is not responsive,
witness answered WE never used physical forms ... he volunteered to include his wife without
any proper question. AFNIE
13) Q20 is “What kind of proper values and manners DO YOU TEACH PATRICK? answer is
not responsive, witness answered is not responsive “We teach him the value of honesty ...” here,
he again volunteered to include his wife without any proper question, there shd be another
question independent thereof. AFNIE
A20. AFNIE
15)
A21. AFNIE
16)Q22,23,24 & 25 shd be stricken out for LPF/LB, the question is also linked to the deleted
answer in A21. AFNIE
17)
A21. AFNIE
A26. AFNIE
A27. If allowed, ...... AFNIE.
20) Q29.....If allowed…. AFNIE
21)Q30 Statement after a Yes answer should be deleted, there should be another question
independent thereof,
22) Q31 is vague and unintelligible question, “What happened” without any connecting words is
not even a complete thought of a sentence. AFNIE
A31. AFNIE
A32 . AFNIE
A28 . AFNIE
26) If all the Q n A are deleted, “ Q35 Shd be stricken out for LPF/ LB/ AFNIE. Was Patrick
ever reprimanded in school for committing bullying acts against Bryce? If allowed, the answer
after the word No shd be deleted ( Patrick was never reprimanded.... against anyone...) for being
volunteered answer sans any proper question independent of the preceding question.
. AFNIE
. AFNIE
29) Q38 shd be stricken out for LPF/LB, the question is also linked to the deleted answer. Again,
in A36. AFNIE
and A38. AFNIE
Q40 shd be stricken out for LPF/LB, the question is also linked to the deleted answer in 39.
31)
AFNIE
Q41 shd be stricken out for LPF/LB, the question is also linked to the deleted answer in A40.
32)
AFNIE
Q42 shd be stricken out for LPF/LB, the question is also linked to the deleted answer in A41 .
33)
AFNIE
. AFNIE
35) Q43 ---LPF/LB/AFNIE also the question is What did YOU do then, if any, after hearing
these... the answer is not responsive, he answered We as he volunteered to include his wife while
it was only him that is being asked what did he do after the meeting. There shd be another
independent question like what abt ur wife what did she do.... but there was none.( In fact, during
the said meeting his wife was silent at all and did not even say a word.) It is improper for the
witness to answer for another person on his direct testimony any person who is not before this
court to appear, testify and take an oath.
in A43 .
in A44.
in A45.
in A46.
in A47
in A48
in A45
43) Q51 shd be stricken off for LPF/LB/AFNIE this is linked to A50 because this question has
not proper foundation as a result of deleted preceding questions .
in A51.
in A52.
46) Q54 shd be stricken out for LPF/LB/AFNIE the question is also linked to the deleted
preceding answers in A50, A51 & A52.
47) Q55 shd be stricken out for LPF/LB/AFNIE the question is also linked to the deleted answers
in A50.
in A50 & succeeding questions that have been stricken off also the question is improper, How
did M. Go destroy your reputation as Patrick’s parents. The question is directed to the witness
and his wife while her wife is not presented to the court to testify. Objectionable bec the witness
volunteered to include in his answer his wife who was not presented in court to testify and to
take an oath.
in A56.
in A56.
in 58.
in A58 & A59
in A54. The question is improper as it assumes ..... mental anguish to all of you...” ( expound ) 5)
Third sentence of Answer No. 20 should be deleted for being unresponsive to the question.
Witness cannot for another person who is not present in court to testify and take her oath.
CROSS-EXAMINATION QUESTIONS ON EUGENE LEE
Caution: Put a cross to the deleted answers and not to ask question thereof
Objective I: To establish lack of time with Patrick Eugene
If Q and A from 8-17 will be allowed by the court.
1) In your Answer to the preliminary question of your JA, you said that you’re working as Senior
Director of a Shared Service Center for a major multi-national company. Does shared service
Center the same as business process outsourcing (BPO) industry or in layman’s term a Call Center
customer service industry, am I right?
Based on your testimony it appears that your work schedule starts in the evening and you go home
in the morning the next day, correct?
By the way, what is your work schedule during those times when Patrick was in Grade 2 at St Jude
and until the time you have executed your JA in February 2014?
Since you are a Senior Director your work requires you to be there for at least eight (or twelve)
hours, is that correct?
In your JA you said that (Answer to Question No. 16) that, “After dinner, I leave for work.” So,
you usually leave for work at about 6PM, am I right?
And during that time your family lived in Caloocan City while your workplace is located in
Muntinlupa, correct?
From Caloocan City (P Jacinto St) to Muntinlupa it would take you more than an hour or about 2
hours travel time, am I correct?
And you still have to travel for more than an hour or (two hours) from home to your workplace
but shorter hour in going home early morning the next day, is that right?
(In your Answer to Question No. 17) You also claimed that you “get home from work early
morning the next day.” So, taking into account your 8 (or 12) hour work schedule and travel time,
you get home at about 6:00AM (or 9AM) in the morning of the next day, am I correct?
While Patrick school schedule when he was Grade 2 in SJCS is from 7:15AM to 4:15PM correct?
And Patrick was a school bus rider, correct?
And this is the yellow big school bus of 50 seater of St Jude that could accommodate about 100
students in a trip?
Patrick has to leave home for school past 6AM because there are a lot of students to be picked up
from Caloocan to Manila where St Jude is located, is that right?
And it would take him more than an hour or two hours of traveling from home to school, vice
versa because he was riding a school bus, is that right?
And since you are working at night, am I correct to say that after coming from work you
immediately take your sleep?
In your Answer to Question No. 14, you said that “when Patrick wakes up in the morning, Joanne
has breakfast with him” and this is a routine. Am I correct to say that you do not routinely take
breakfast with them because you are either still at work or still sleeping by that time they take
breakfast?
In other words, your statements in Answer No. 14 are not based on your personal knowledge
because you are either still at work or sleeping by that time your son Patrick Eugene wakes up and
until he leaves for school, am I correct?
Your time with Patrick routinely starts only “when Patrick gets home from school” as stated in
Answer No. 15 of your JA, is that correct?
And when Patrick was in Grade2 he would able to get home from school past 6PM ?
While you have to leave for work at about6PM?
Also during that time when Patrick was in Grade 2 you mentioned your wife was working as Asst
Bank Manager in a bank, is that right?
Since she was holding a managerial position, she also works more than 8 hours a day, am I right?
Taking into account the travel time your wife usually arrives home from work past 7PM or 8PM,
is that right?
In other words, you routinely spend about an hour only with your son Patrick during weekdays?
With that short hour you could not possibly supervise his activities when he arrives home from
school, is that right?
Objective II: To establish that he is neglect or remiss in supervising the activities of Patrick Eugene
at home
Do you have a computer or laptop at home?
Does Patrick Eugene Lee have access to this computer or laptop?
Can he operate and use this computer or laptop alone?
Do you know if Patrick Eugene has a Facebook account at the time when he was in Grade II?
(Follow up: If yes, are you aware of the language of Patrick Eugene in his conversations using his
FB account?
If no, is it correct to say that you did not monitor the conversation of Patrick Eugene Lee with
other persons using online media such as FB?)
I will show you the conversation log print outs of one Patrick Eugene Lee in the FB account, for
identification. These print outs were stricken out but already tendered or proffered during the time
plaintiff was presented to the stand on a mere ground of relevancy because according to the court
the conversations did not involve Bryce but their other classmates that’s why they were irrelevant.
However, we intend to present these again during the rebuttal. And I will confront the witness to
ascertain the truthfulness of his testimony now. As shown by these screen shots, would you tell us
if this is the picture of your son Patrick?
Would you agree with me that your complete home address in your JA and the address posted in
Patrick FB account is the same? Is that right?
Are you are aware of this conversation? (Confront with screenshots)
21) You said in your Answer No. 19 of your JA that you “spend time to explain to him clearly
what is right and what is wrong and the consequences when he does not do what is right”. Did you
explain to Patrick the right way to converse in his FB account?
In the conversation posted on Patrick FB did you supervise him when he posted ______
What about his post that _______, did you supervise Patrick on this?
Did you not bother to delete those posts upon learning of its existence? Or you were not totally
aware of those bec you didn’t supervise him at all in his social media usage?
Were you aware that his FB account was in public setting, so that anyone who has a Facebook
account can see his posts?
Would you agree with me that Patrick’s safety and your family security is primordial to you
concern, is that right?
But do you also agree with me that when Patrick posted your complete address in this FB account
he put the family privacy and security at a risk?
22) Do you have a phone at home?
23) Does Patrick Eugene have access to this phone?
24) Can he use and make calls with this phone?
25) How do you explain to Patrick Eugene the right way to converse with others over the phone?
26) Have you heard Patrick Eugene converse with Bryce Wayne Go over the phone?
27) Have you heard Patrick Eugene utter foul or cuss words to Bryce Wayne Go over the phone?
(Follow up: If yes, what did you do? If no, is it correct to say that you did not monitor or supervise
the conversation of Patrick Eugene Lee with other persons over the phone?)
Objective III: To establish that his version of the complained acts and of the March 8, 2011 incident
is contrary to the factual findings of the school
Are you aware that aside from you and your wife, St Jude and its four school personnel were also
defendants in the instant case?
Did you read the Complaint in the instant case?
Did you also read you and your wife Answer to the Complaint?
Did you also read the Answer of St Jude in this case?
What about the Answer of Nicasio, de Lara, Iglesia and De Guzman were you able to read their
Answer to the Complaint?
You mentioned in your JA that Patrick version of the story is consistent with the version of the
school personnel, is that right?
When you said school personnel you referred to your co- defendants in the instant case, right?
In the Answer of defendant St Jude it stated that.....
In the Answer of the school personnel it stated that.....
Therefore your versions of the incident were inconsistent to their version and not the way you
claimed it to be, isn’t it?
28) In your Answer to Question No. 29, you stated that “Patrick would never forcibly take, through
threat or intimidation, Bryce’s money and personal things or that of other St. Jude students” and
in your Answer to Question No. 34, you stated that “Patrick would never commit bullying acts to
Bryce or to other St. Jude students for that matter”.
Would you agree that the taking of money and personal things and the bullying acts of Patrick
Eugene on Bryce was investigated by the school, thru its Prefect of Discipline? Better to confront
the letters of the charge sheet
29) Also, in your Answer to Question No. 38, you stated the version of Patrick Eugene Lee about
the March 8, 2011 incident is that “while they were playing wrestling, Bryce tried to toss Patrick
over by slinging Patrick’s arm over his shoulder.” Would you agree with me that this March 8,
2011 incident was also investigated by the school, thru its Prefect of Discipline?
30) In fact, the Prefect of Discipline of Saint Jude has formally charged, thru a charge sheet, Patrick
Eugene after he conducted an investigation about the complained acts and the March 8, 2011
incident against you son, is that correct?
31) And this charge sheet was in fact served upon you by the Prefect of Discipline, Mr. Anthony
de Lara, which stated the acts committed by you son which he had threshed out after he conducted
an investigation, is that correct?
32) I am showing to you a copy of the charge sheet attached to the Answer of defendants Nicasio,
et. al., do you confirm that this is the charge sheet served upon you by the Prefect of Discipline,
Mr. Anthony de Lara?
33) What did you tell Patrick Eugene after you received the charge sheet? better yes or no question
34) Patrick Eugene submitted his written explanation to this charge sheet, is that correct?
35) You assisted and guided Patrick Eugene in preparing and submitting his written explanation
to the charge sheet, is that correct?
36) I am showing to you a copy of the written explanation of Patrick Eugene to the charge sheet,
bearing his, yours, and your spouse’s signatures, and this which was attached to the Answer of
your co-defendants, do you confirm that this is the written explanation that Patrick Eugene,
assisted by you and your wife Joanne, has executed and submitted to the Prefect of Discipline of
Saint Jude?
37) After you submitted your written explanation, you mentioned that the school meted the penalty
of Conduct C and probation on Patrick Eugene, do you confirm this?
And this penatly was reduced into writing in a Decision rendered by the school, is that correct?
And you were given a copy of the said decision?
In gist, in the said decision the school resolved that it did not give credence to the written
explanation submitted by Patrick which you and your wife assisted, is that correct?
Therefore he was found liable to the charges against him, do you confirm this?
Also in the said Decision, ________, is that correct?
You have totally forgotten the content of the said Decision?
Was isn’t important to you to recall the contents of the said Decision?
38) Now, you mentioned that Patrick did not took the money and personal things of Bryce, that
Patrick did not commit bullying acts on Bryce, and that Patrick did not physically hurt Bryce on
March 8, 2011;
Did you move for a reconsideration of the decision of the school which imposed a penalty of
Conduct C and probation on Patrick Eugene?
39) And despite the decision of the school imposing the penalty of Conduct C and probation on
Patrick Eugene, you also did not interpose an appeal to higher authorities?
40) In the light of the decision of the school imposing upon Patrick Eugene the penalty of Conduct
C and probation, do you still maintain your stand that Patrick Eugene did not took the money and
personal things of Bryce?
41) Do you also still maintain that Patrick Eugene did not commit bullying acts on Bryce despite
the decision of the school imposing the penalty of Conduct C and probation on your son?
42) Do you also still maintain that Patrick Eugene did not physically hurt Bryce on March 8, 2011
despite the decision of the school imposing the penalty of Conduct C and probation on your son?
43) Do you have a copy of the decision of the school? (Follow up: If yes, could you produce and
submit it in this court for our examination?)
Also in your JA, you did not even bother to attach the Charge Sheet and Patrick’s written
explanation, is that right?
Objective IV: To establish that he and the school did not impose sanctions on prior incident
wherein Patrick Eugene took and used the money of his classmate
44) In your Answer to Question 31, you narrated about an incident wherein Patrick Eugene asked
his classmate to buy him a book and this classmate ended up short on cash to purchase his own
book. How did you come to know about that incident?
45) You also said in your Answer to Question 32 that the school merely asked you to reimburse
the student for the cost of the book. So, is it correct to say that the school did not impose any
disciplinary action on Patrick Eugene for asking his classmate to buy him a book which resulted
in this classmate of him ending up short on cash to buy a book of his own?
46) In fact, the school did not issue any charge sheet against Patrick Eugene with respect to that
incident, is that correct?
47) As found by the school Prefect of Discipline, the action of Patrick Eugene in taking and using
the money of his classmate was committed again when he did it to Bryce and his classmates in
Grade II; did you just want to reimburse the other kids this time around?
In fact, in your written explanation you said that Patrick should ask from his parents for money,
rather than to be contented with his own allowance.
Objective V: To establish his own perception of how effective he guides and disciplines Patrick
Eugene in the light of the decision of the school
48) In your answer to Question No. 53, you said that you taught proper values and manners to
Patrick Eugene.
These values and manners you allegedly taught him did not suit well to Patrick’s FB posts like I
will kill Jetrix .....
49) You also stated that you showered him with enough love, attention, guidance and time. Would
you agree with me that your enough love, attention, guidance and time did not suit well in his FB
posts that....
50) When the school came up with the decision that Patrick Eugene was found guilty of committing
the acts charged upon him, do you still consider yourself not to have been remiss in your parental
duties to him? (Follow up: If yes, so you did not take new or additional steps to guide your son
Patrick Eugene? If no, that’s it!)
Objective VI: To disprove his counterclaim
51) In your Answer to Question No. 56, you stated that Atty. Go made it appear to St. Jude, its
administrators, teachers, staff, co-parents and other students that you and your wife are not good
parents, and that you even teach and encourage Patrick Eugene to do wrong to others through
bullying and forcibly taking others’ money and personal things, do you confirm that?
52) In you Answer to Question No. 57, you stated that Atty. Go repeatedly informed St. Jude, its
administrators, its administrators, teachers, staff, co-parents and other students that Patrick bullied
Bryce and has been forcibly taking money, do you confirm that?
53) When you say Atty. Go “made it appear” to them and that she “repeatedly informed” them,
what do you mean by that? (Follow up: Do you have personal knowledge? How?)
Did you see me campaigning?
Was it because I sent a formal letter of complaint to the school authorities that for you it was
campaigning?
Was it because I asked for the formal investigation of what happened to my son during the time
Bryce got physically, emotionally and mentally hurt in the school, was it campaigning to you?
You accused plaintiff of campaigning without a single proof to support of your claim, isn’t it?
You are an alumnus of St Jude, right?
Graduated in 1988?
Just like you, you want your son Patrick to graduate at St Jude, isn’t it?
54) Is it not a fact that the bullying and taking of others’ money and property committed by you
tson against Bryce and other students was investigated by the school, thru defendant Anthony de
Lara?
55) In fact, and as plaintiff only came to know when this case was already filed, you and your son
were given a chance to answer the charges against him the basis of which were threshed out after
defendant de Lara has conducted an investigation and interview with several students, is that right?
56) Thereafter, the school came up with a decision which meted the penalty of conduct C and
probation on your Patrick Eugene and you did not move for any reconsideration or interpose an
appeal, is that right?
57) Despite the decision of the school against your son, you still maintain that the charges of
bullying and taking of money committed by your son are false?
58) Do you usually insist on the version of your son even when the evidence and the investigation
findings are contrary to what he has told you?
59) Mister witness, do you consider yourself as having the primary duty to guide and discipline
Patrick Eugene not to bully others or not to take others’ money and property?
60) Now, you also mentioned that the incident and the filing of the case were even caused to be
published in a newspaper of general circulation, isn’t it?
61) Did you bother to check or verify with the publisher of that newspaper who caused the
publication?
62) Did you also bother to check with the publisher had Atty. Go had asked that the publication be
removed because it was done without her consent and it unduly provided information about her
personal circumstances particularly her residential address was shown and published in that
newspapers?
Did you notice that the publication was a brief and undetailed story of the instant complaint?
And you didn’t even bother to ask the publisher where did they get their source, isn’t it?
And without any effort on your part or any proof to substantiate your claim you would unjustly
accused that it was herein plaintiff who caused the said publication, isn’t it?
Are you aware that herein plaintiff’s claim for damages is about 1.2M in totality?
While you are demanding a total of 17M as your counterclaim, is that right?
Do you have a professional license issued in the Phils just like the plaintiff, a lawyer by profession?
How did you come up with the said 10M moral damages, where in fact it is your son who continued
to study at St Jude after the incident in 2011 while Bryce had to immediately leave the school?
What was your basis of your 5M claim for exemplary damages while_______....?
What was your basis of your 2M atty’s fees while you did not present supporting documents that
you have spent 2M by way of atty’s fees?
Is that the way you teach your child Patrick how to earn or get money from others?

Objections 9.1.18

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Objections 9.1.18

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9.01.

OBJECTIONS TO THE JUDICIAL AFFIDAVIT OF EUGENE LEE

2) In Q9, If the preceding answer (A8) has been stricken

20) Q29.....If allowed…. AFNIE

54) Q62 is linked to A55, 63 to 62, 64 linked to A50.

CROSS-EXAMINATION QUESTIONS ON EUGENE LEE

Objective I: To establish lack of time with Patrick Eugene

If Q and A from 8-17 will be allowed by the court.

And Patrick was a school bus rider, correct?

While you have to leave for work at about6PM?

Do you have a computer or laptop at home?

Does Patrick Eugene Lee have access to this computer or laptop?

Can he operate and use this computer or laptop alone?

Are you are aware of this conversation? (Confront with screenshots)

22) Do you have a phone at home?

23) Does Patrick Eugene have access to this phone?

24) Can he use and make calls with this phone?

Did you read the Complaint in the instant case?

Did you also read the Answer of St Jude in this case?

In the Answer of defendant St Jude it stated that.....

In the Answer of the school personnel it stated that.....

And you were given a copy of the said decision?

Also in the said Decision, ________, is that correct?

You have totally forgotten the content of the said Decision?

Did you see me campaigning?

You are an alumnus of St Jude, right?

OBJECTIONS TO THE JUDICIAL AFFIDAVIT OF EUGENE LEE

2) In Q9, If the preceding answer (A8) has been stricken

20) Q29.....If allowed…. AFNIE

CROSS-EXAMINATION QUESTIONS ON EUGENE LEE

Objective I: To establish lack of time with Patrick Eugene

If Q and A from 8-17 will be allowed by the court.

Do you have a computer or laptop at home?

Does Patrick Eugene Lee have access to this computer or laptop?

Can he operate and use this computer or laptop alone?

Are you are aware of this conversation? (Confront with screenshots)

22) Do you have a phone at home?

23) Does Patrick Eugene have access to this phone?

24) Can he use and make calls with this phone?

Did you read the Complaint in the instant case?

Did you also read the Answer of St Jude in this case?

In the Answer of defendant St Jude it stated that.....

In the Answer of the school personnel it stated that.....

And you were given a copy of the said decision?

Also in the said Decision, ________, is that correct?

You have totally forgotten the content of the said Decision?

Objective VI: To disprove his counterclaim

Did you see me campaigning?

You are an alumnus of St Jude, right?

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