Republic of the Philippines

REGIONAL TRIAL COURT

City of Silang, Cavite
Branch 28

DOCKET NO. L-1234567

BEA ALPOMBRA
Plaintiff

- versus- FOR: VIOLATION OF R.A. No. 7610

on Child Abuse
GERALD ALPOMBRA
Accused

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JUDICIAL AFFIDAVIT
(of Defense witness MARIA REYES in lieu of Direct Testimony)

I, MARIA A. REYES, 29 years old, born on June 2, 1990, married, living at 123 C.M.
Recto St., Silang, Cavite City, after having been duly sworn to in accordance with law,
hereby depose and state:

PRELIMINARY STATEMENT

That in accordance with A.M. No. 12-8-8-SC, which prescribes the use of judicial
affidavits to serve as the direct examination testimony of the witness, on the basis of which
the adverse party may conduct their cross-examination on such a witness, I hereby
execute this judicial affidavit in a question and answer format;

That conformably with section 3 (b) if the said A.M. No. 12-8-8-SC, I also state that it
was Atty. Renato Cruz, with address as Makati City, Philippines. The examination being
held at the same address, who conducted the examination.

That conformably also with section 3 (c) thereof, I hereby state under the pain of
perjury that in answering the question asked of me, as appearing herein below, I am fully
conscious that I did so under oath, and that I may face criminal liabilities for false testimony
or perjury.

AND UNDER OATH, AVERS THE FOLLOWING:

1. Q: Mrs. Witness, will you state your name and other personal circumstances?
A: I am Maria Reyes, 29 years old, living at 23 C.M. Recto St., Silang, Cavite City.
2. Q: Why are you here today?
A: I am here as a witness of Mr. Alpombra
3: Q: How do you know Mr. And Mrs. Alpombra?
A: I am their house helper.
4: Q: Do you know why you are called upon to witness today?
A: Yes
5. Q: Can you tell us why?
A: Because Mrs. Alpombra filed a case against Mr. Alpombra for child abuse
6. Q: Ms. Witness, can you describe to us the relationship of Mr. And Mrs. Alpombra?
A: They have a bad relationship. They fight a lot.
7. Q: How long have you been working with the spouses Alpombra?
A: I have been working for 3 years.
8. Q: And how many hours do you work for them?
A: I work from 6am to 8pm every day
9. Q: Based on your personal knowledge and based from what you have witnessed
while you are working with the Alpombra family, how do you describe Mr. and Mrs.
Alpombra’s fights?
A: They usually fight after Mr. Alpombra comes from work during the night when Mr.
Alpombra asks Ms. Alpombra to prepare him dinner and Mrs. Alpombra would
refuse.
10. Q: Ms. Witness, do you know that Ms. Alpombra alleged in her complaint that it is
Mr. Alpombra who is abusive?
A: Yes.
11. Q: what can you say about that?
A: It is not true at all.
12. Q: What do you say so?
A: Because I have witnessed a lot of their fights and It is really Mrs. Alpombra who
initiated the fights.
13. Q: So you are saying now that it is actually Mrs. Alpombra who is the instigator of
their fights, is that correct?
A: Yes.
14. Q: Can you explain to us why do you say so?
A: Because it is Mrs. Alpombra who always gets mad at Mr. Alpombra.
15. Q: Can you tell us what acts did Mrs. Alpombra do for you to say that it is her who is
the instigator?
A: She is always grumpy whenever Mr. Alpombra would approach and talk to her,
she always gets mad easily and sometimes she would go hysteric over petty things.

16. Q: What can you say about the allegations of Mrs. Alpombra that Mr. Alpombra is
the cause of the psychological problems that their children are experiencing?
A: It is not true. Mr. Alpombra has a good relationship with his children.
17. Q: Were there instances when Mr. Alpombra physically maltreated his children, if
any?
A: None. Not that I know of.
18. Q: How about verbally?
A: None.
19. Q: How about Mrs. Alpombra? Were there instances of verbal maltreatment to the
children?
A: Sometimes when they are in the middle of the fight, Mrs. Alpombra would vent
her anger towards the children.
20: Q: And how did the children reacted?
A: The children would just cry and beg for the couple to stop.
21. Q: Did the children say anything to you about their parents, If any?
A: The children told me about how they would get afraid of them whenever they fight
22. Q: I have no further questions. Do you have any statements to add or take away on
this affidavit?
A: I don’t have.
23. Q: Are you willing to sign this affidavit consisting of 4 pages, to certify that all
statements you made are true?
A: Yes.

-------------- END OF STATEMENT ---------------

IN WITNESS WHEREOF, I hereunto set my hand below this 11th day of September,
2018 at Makati City, Philippines.

MARIA A. REYES
Affiant
 ATTESTATION CLAUSE

I, ATTY. RENATO CRUZ, hereby attest that I faithfully recorded the questions
propounded and the corresponding answers given by the witness MARIA A. REYES. I duly
interpreted the questions I asked in the tagalog dialect which the witness understands as
she provided the answers the best way she could which were duly translated by me in the
English Language. I did not in any way coach or taught or instruct the witness on how to
answer or any other person or persons then present or assisting the witness regarding the
latter’s answers.

ATTY. RENATO CRUZ

Issued on September 11, 2018

SUBSCRIBED AND SWORN TO before me this 11th day of September, 2018 at

Silang, Cavite City, Philippines. Further, I certify that I personally examined the herein
affiant that he voluntarily executed and fully understood his statements.

ATTY. JOSEPH L. CRUZ

Issued on September 11, 2018