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SCRIPT Frustrated Murder

PROSECUTOR ANTHONY PRESTOZA: For the government.

People vs. Merin

ATTY. TAPIRE: For the defense.

CHARACTERS:

COURT: Ready?

Ayn Sarsaba -Prosecution Counsel

PROSECUTOR ANTHONY PRESTOZA: Ready Your Honor.

Anthony Prestoza - Prosecution Counsel

COURT: Call your witness to the witness stand.

Katherine Jane Manarang -Complainant

PROSECUTOR ANTHONY PRESTOZA: May I call on Catherine Jane Manarang.

Richard Alvin Nalupta- Boyfriend of the Complainant (Prosecution Witness)
Dr. Juan Paolo Gascon -Expert Witness

INTERPRETER: Do you swear to tell the truth, all the truth and nothing but the
truth in this case?

Analita Ocampo -Defense Counsel

WITNESS: Yes, sir.

Helen Paulette Tapire- Defense Counsel

COURT: Please state your name and other personal circumstances.

Iris Victoria Merin - Accused
Leira Taruc- Expert Witness
Catherine Bool- Nunez -Officemate of Complainant (Defense Witness)

PROSECUTION
MANARANG
PRESTOZA

COURT: Call the case.
INTERPRETER: For hearing, Criminal Case No. 12345, People of the Philippines
vs. Iris Victoria Merin.
COURT: Appearances.

WITNESS: Catherine Jane Manarang, 28 years of age, single, a Certified Public
Accountant of the Accounting Division of Nestle Philippines and a resident of Unit
143 Astral Apartment Padre Faura St. Ermita, Manila.
COURT: Your witness.

Joel Macalino

DIRECT EXAMINATION OF CATHERINE JANE
(COMPLAINANT)
BY
PROSECUTOR
ANTHONY
(PROSECUTION COUNSEL)

COURT: Swear in the witness.

PROSECUTOR ANTHONY PRESTOZA: The witness is being presented to testify
on the fact that the accused bought the rat killer and that the substance that poisoned
her was from the grapefruit juice which the accused prepared. May we proceed Your
Honor?
COURT: Proceed.
PROSECUTOR ANTHONY PRESTOZA: Catherine Jane Manarang, will you
please tell this Honorable Court where you were on October 17, 2007 at around 8
o’clock in the morning?

CATHERINE JANE MANARANG: I was in our apartment at Unit 143 Astral
Apartment Padre Faura St. Ermita, Manila.
PROSECUTOR ANTHONY PRESTOZA: Who lives in that apartment?
CATHERINE JANE MANARANG: I and my best friend, Iris Victoria Merin.
PROSECUTOR ANTHONY PRESTOZA: Who was with you at that particular
time of the day?
CATHERINE JANE MANARANG: I was alone because I did not report for work
to prepare for my engagement party.
PROSECUTOR ANTHONY PRESTOZA: How did you prepare for the party?
CATHERINE JANE MANARANG: I decided to clean the house.
PROSECUTOR ANTHONY PRESTOZA: And what particular areas of the house
did you clean?
CATHERINE JANE MANARANG: I cleaned the living room and the CR first.
Then I cleaned the dirty kitchen. Because I remembered Iris said something like
Dumadami na yung mga rodents sa dirty kitchen.”

PROSECUTOR ANTHONY PRESTOZA: Have you actually seen any rats in your
place? A: No. Actually, it made me wonder€¦ I just relied on the word of Iris. Besides,
in our lease agreement, there was a stipulation that it shall be the owners
responsibility to conduct quarterly pest control measures.
PROSECUTOR ANTHONY PRESTOZA: I am showing to you this document
previously marked as Exhibit A. Please go over this document and tell this Honorable
Court if this is the lease agreement you are referring to.
CATHERINE JANE MANARANG: Yes, this document is the lease agreement.
PROSECUTOR ANTHONY PRESTOZA: Whose signature is this above the
printed name Catherine Jane Manarang which is appearing on page 2 of this contract
of lease?
CATHERINE JANE MANARANG: My signature, sir.
PROSECUTOR ANTHONY PRESTOZA: And this signature belongs to whom?
(Prosecutor Prestoza pointing at the right portion of the document)
CATHERINE JANE MANARANG: Our lessor, Mr. Rhandell Matuloy.

PROSECUTOR ANTHONY PRESTOZA: The last place you cleaned was the dirty
kitchen?

PROSECUTOR PRESTOZA: Which for purposes of identification, Your Honor, I
would like to request the marking of the signature appearing above the printed name
of Catherine Jane Manarang as Exhibit A-1.

CATHERINE JANE MANARANG: Yes, Your Honor.

COURT: Mark it.

PROSECUTOR ANTHONY PRESTOZA: What did you do in order to solve the
problem on the rats?

PROSECUTOR ANTHONY PRESTOZA: And the signature appearing above the
printed name of Rhandell Matuloy as the lessor be marked as Exhibit A-2.

CATHERINE JANE MANARANG: I used a rat killer, Your Honor.

COURT: Mark it.

PROSECUTOR ANTHONY PRESTOZA: Who bought the rat killer?

PROSECUTOR ANTHONY PRESTOZA: We would also like to request for the
marking of stipulation no.8 in this lease agreement as Exhibit A-3.

CATHERINE JANE MANARANG: Iris bought it because she told me that she
noticed that there were rats in the place.

COURT: Mark it.

that would make about 600-700 mL. We spent the whole afternoon together until we decided to go home for the party. So. OCAMPO: Objection. the pitcher. PROSECUTOR ANTHONY PRESTOZA: What happened next? . PROSECUTOR ANTHONY PRESTOZA: What time did you leave Starbucks? PROSECUTOR ANTHONY PRESTOZA: When did you drink the said beverage? CATHERINE JANE MANARANG: Before I went to Starbucks. I complained to Iris that my head was aching. previously marked as Exhibit B was recognized by the victim as the pitcher containing the grapefruit juice prepared by the accused for the complainant. The dinner party was set at 6 o’clock that evening. PROSECUTOR ANTHONY PRESTOZA: What happened later? CATHERINE JANE MANARANG: I drank about 2 glasses. PROSECUTOR ANTHONY PRESTOZA: Did your friend say anything? CATHERINE JANE MANARANG: Yes. I rested because I got tired. PROSECUTOR ANTHONY PRESTOZA: Can you estimate the amount of juice you drank? PROSECUTOR ANTHONY PRESTOZA: Was your fiance with them? CATHERINE JANE MANARANG: A glass would contain about 300-350 mL of liquid. PROSECUTOR ANTHONY PRESTOZA: Where did you find the grapefruit juice? CATHERINE JANE MANARANG: Inside the ref. Your Honor! Question is leading. CATHERINE JANE MANARANG: Yes. will you be able to recognize it? (lawyer takes the pitcher showing it to the victim) PROSECUTOR ANTHONY PRESTOZA: What else did you do on that day? CATHERINE JANE MANARANG: I went out to meet Iris for our usual coffee break in Starbucks at 3 o’clock in the afternoon. PROSECUTOR ANTHONY PRESTOZA: What happened next? CATHERINE JANE MANARANG: After cleaning. COURT: Sustained. PROSECUTOR ANTHONY PRESTOZA: For the record. PROSECUTOR ANTHONY PRESTOZA: If that pitcher containing the grapefruit juice will be shown to you. PROSECUTOR ANTHONY PRESTOZA: Did you feel anything at that time? ATTY. she told me not to forget to drink the grapefruit juice she prepared for me. PROSECUTOR ANTHONY PRESTOZA: What happened at Starbucks? CATHERINE JANE MANARANG: While were eating. that’s the one. CATHERINE JANE MANARANG: The guests arrived. We entertained them. I remembered that before Iris left that morning for work. CATHERINE JANE MANARANG: She told me that I was just tired.PROSECUTOR ANTHONY PRESTOZA: Was there consistent compliance by the owner? CATHERINE JANE MANARANG: Yes. PROSECUTOR ANTHONY PRESTOZA: How many glasses were you able to drink? CATHERINE JANE MANARANG: 5 o’clock PROSECUTOR ANTHONY PRESTOZA: What time did you arrive in your apartment? CATHERINE JANE MANARANG: We arrived at about 5:30 o’clock in the late afternoon.

I put the rat poison in some rice and then I put the rice on the floor so that the rats could eat them. CATHERINE JANE MANARANG: Yes. COURT: Cross? ATTY. ANALITA OCAMPO: After cleaning the dirty kitchen? CATHERINE JANE MANARANG: Yes. ANALITA OCAMPO( DEFENSE COUNSEL) ATTY. August. PROSECUTOR ANTHONY PRESTOZA: Did anyone come to help? ATTY. as you have said earlier? . you testified that in cleaning the dirty kitchen. May. ATTY. CATHERINE JANE MANARANG: I took the pack out of the box. Your Honor. PROSECUTOR ANTHONY PRESTOZA: So. ANALITA OCAMPO: Not right after you put the poison into the rice. you still did not use any protection for your hands? CATHERINE JANE MANARANG: Yes. Then I put some into my hand. ATTY.CATHERINE JANE MANARANG: I approached Iris and chatted with her. if the accused is inside this courtroom. ATTY. ANALITA OCAMPO: How did you use the rat poison? CATHERINE JANE MANARANG: Before I totally lost consciousness. PROSECUTOR ANTHONY PRESTOZA: What did you feel at that time? CATHERINE JANE MANARANG: My headache worsened. I saw that Iris was smiling while she held on to me. you testified that in the lease contract. ANALITA OCAMPO: You did not use any gloves to protect your hands or your skin? CATHERINE JANE MANARANG: No. PROSECUTOR ANTHONY PRESTOZA: Did you notice anything else? ATTY. you used a rat poison to kill the rats there. ANALITA OCAMPO: Miss Witness. I felt so weak that I lost my balance. Sir. OCAMPO: Yes. How often is this pest control conducted? CATHERINE JANE MANARANG: Quarterly. CROSS EXAMINATION OF CATHERINE JANE MANARANG(COMPLAINANT) BY ATTY. ANALITA OCAMPO: Miss Witness. PROSECUTOR ANTHONY PRESTOZA: That is all. ATTY. Is that right? CATHERINE JANE MANARANG: Yes. Your Honor. ANALITA OCAMPO: And during what months did the lessor conduct these pest control measures? CATHERINE JANE MANARANG: February. ANALITA OCAMPO: Miss Witness. even if you knew that. Your Honor. because I planned to wash my hands after I cleaned the dirty kitchen. I began to feel nauseous and I vomited. (Victim pointed to the accused. Your Honor. Your Honor. and November of every year. Iris caught me before I hit the floor. CATHERINE JANE MANARANG: Yes. the lessor had the responsibility to conduct pest control measures. ANALITA OCAMPO: So. did you know that a rat poison could also poison humans if accidentally swallowed? ATTY.) There. Your Honor. Your Honor. would you be able to identify and point to her? CATHERINE JANE MANARANG: Yes. ATTY.

What was the color of the juice? CATHERINE JANE MANARANG: Yellow. ATTY. a bit bitter. ANALITA OCAMPO: Was your sight still clear? ATTY. ATTY. ATTY. ATTY. ATTY. The grapefruit juice really has a slight bitter taste. ANALITA OCAMPO: So you cannot see clearly at the time you fell to the ground? CATHERINE JANE MANARANG: Yes. and then you vomited and fell to the floor. ANALITA OCAMPO: Were you not really tired after cleaning the entire house? CATHERINE JANE MANARANG: Yes. ANALITA OCAMPO: Bitter? CATHERINE JANE MANARANG: Yes. Your Honor. Is that right? CATHERINE JANE MANARANG: Yes. Your Honor. Your Honor. because I was so dizzy. Your Honor. ANALITA OCAMPO: You testified that before the accused left the house. ATTY. Your Honor. she told you not to forget to drink the juice. INTERPRETER: Did you not wonder why the juice was bitter? ATTY. Your Honor. We often leave food and drinks for each other. Both of us used to do that.CATHERINE JANE MANARANG: Yes. Your Honor. when she told you not to forget to drink the juice. ATTY. ANALITA OCAMPO: You testified that you drank the grapefruit juice. Your Honor. ANALITA OCAMPO: You also said that at the party you felt nauseous. perhaps because it was so sour. Your Honor. it was nothing new to you. ATTY. ATTY. Your Honor. what was its taste? CATHERINE JANE MANARANG: It was sour. were you still conscious? CATHERINE JANE MANARANG: No. did you notice anything different about her? CATHERINE JANE MANARANG: Yes. CATHERINE JANE MANARANG: Yes. CATHERINE JANE MANARANG: I’m not sure Your Honor. ANALITA OCAMPO: What was that? CATHERINE JANE MANARANG: When I complained about my headache. ANALITA OCAMPO: So you cannot possibly say that Iris was really smiling when she held you? CATHERINE JANE MANARANG: Yes. she just told me that I was just tired. ANALITA OCAMPO: You testified that at 3 pm on October 17. because both of you had that habit. ANALITA OCAMPO: So. When you were with the accused. . ATTY. I was quite tired. Your Honor. ATTY. ANALITA OCAMPO: When you were already at the floor. CATHERINE JANE MANARANG: Yes. ANALITA OCAMPO: When you drank the juice. ANALITA OCAMPO: Hindi ka ba nagtaka at mapait yung juice na ininom mo? PROSECUTOR PRESTOZA: Objection: Your Honor! My witness cannot understand Filipino. 2007 you met with the accused at a coffee shop. COURT: Let the question be translated for the witness. ATTY. Has she done this even before the incident happened? CATHERINE JANE MANARANG: A bit blurry.

all the truth and nothing but the truth in this case? . ATTY. Ocampo showing the summary discharge report to the complainant) CATHERINE JANE MANARANG: Yes. CATHERINE JANE MANARANG: I went through psychological counseling sessions. have you ever visited a psychiatrist? CATHERINE JANE MANARANG: Yes. she gave me anti-depressant pills. You may step down. Taruc? (Atty. We will call on our next witness. CATHERINE JANE MANARANG: I needed treatment for my depression. Your Honor. Your Honor. INTERPRETER: Do you swear to tell the truth. ANALITA OCAMPO: Did your psychiatrist prescribe any medication? ATTY. did anything happen before you visited your psychiatrist? ATTY. ANALITA OCAMPO: Who was the doctor who treated you? ATTY. ATTY. ANALITA OCAMPO: Where is her clinic located? ATTY. ANALITA OCAMPO: Are you still taking these medications? CATHERINE JANE MANARANG: Dr. the complainant has identified Exhibit 1 which was previously marked as Summary Discharge Report at the Medical Center Manila. Leira Taruc. Your Honor. ANALITA OCAMPO: Were this counseling sessions reduced into writing? DIRECT EXAMINATION OF RICHARD NALUPTA (BOYFRIEND OF THE COMPLAINANT PROSECUTION WITNESS) BY PROSECUTOR ANTHONY PRESTOZA (PROSECUTION COUNSEL) CATHERINE JANE MANARANG: Yes. ANALITA OCAMPO: For the record. ANALITA OCAMPO: Miss Witness. Taruc who prepared the report. ATTY. Richard Alvin Nalupta. ANALITA OCAMPO: When was this? ATTY. ATTY. COURT: Re-direct? ATTY. ANALITA OCAMPO: Who prepared this medical report? CATHERINE JANE MANARANG: Around August 2006. ANALITA OCAMPO: Miss Witness. and I blamed myself for their death. Your Honor. ATTY. Your Honor. ANALITA OCAMPO: What did this Dr. ANALITA OCAMPO: No further questions. Your Honor. CATHERINE JANE MANARANG: My parents died of a terrible accident. ANALITA OCAMPO: What was the cause of your depression? CATHERINE JANE MANARANG: I committed suicide. ATTY. PROSECUTOR ANTHONY PRESTOZA: I’m calling on Mr. ANALITA OCAMPO: Why did you go to such psychiatrist? CATHERINE JANE MANARANG: It was Dr. Your Honor. CATHERINE JANE MANARANG: At the Medical Center Manila. ATTY. COURT: Miss Witness. CATHERINE JANE MANARANG: Not anymore. ANALITA OCAMPO: Is this document the record of the treatment you went through under Dr. Taruc do to treat you? PROSECUTOR PRESTOZA: No. Call your next witness.ATTY. Your Honor CATHERINE JANE MANARANG: Yes. Your Honor. ATTY.

are there any persons around? RICHARD NALUPTA: Yes. Iris was there. RICHARD NALUPTA: She is the childhood friend of the complainant. RICHARD NALUPTA: Not always. PROSECUTOR ANTHONY PRESTOZA: How are you related to her? PROSECUTOR ANTHONY PRESTOZA: What do you mean when you said that the complainant was not always there? RICHARD NALUPTA: She is my fiancé. sometimes. RICHARD NALUPTA: Yes. officemate. May we proceed. was the complainant always there? RICHARD NALUPTA: Yes. COURT: Your witness. PROSECUTOR ANTHONY PRESTOZA: How often do you visit the complainant? RICHARD NALUPTA: During weekdays. San Miguel Quiapo. PROSECUTOR ANTHONY PRESTOZA: Do you know the accused? RICHARD NALUPTA: She’s not there because she went out. Your Honor. PROSECUTOR ANTHONY PRESTOZA: Whenever you visit the complainant in their apartment. PROSECUTOR ANTHONY PRESTOZA: Do you visit the complainant in their apartment? RICHARD NALUPTA: Yes. single. Your Honor. and they live in the same apartment. PROSECUTOR ANTHONY PRESTOZA: Do you know the complainant? PROSECUTOR ANTHONY PRESTOZA: When you visit the complainant during weekend. ATTY. PROSECUTOR ANTHONY PRESTOZA: And whenever that happens.RICHARD NALUPTA: Yes Sir. Your Honor. Richard Nalupta is presented to testify on the fact that the accused secretly fell in love and could possibly be obsessed with him and may likewise began to hate the complainant secretly. COURT: Please state your name and other personal circumstances. 30 years of age. Your Honor. Your Honor. Your Honor. Your Honor? COURT: Proceed. PROSECUTOR ANTHONY PRESTOZA: Where or in what particular part of the apartment do you wait? . PROSECUTOR ANTHONY PRESTOZA This witness. Manila. whenever I drop her after work. RICHARD NALUPTA: Ritchie Nalupta. PROSECUTOR ANTHONY PRESTOZA: Mr. Witness. head security officer of the Security Services Division of Nestle Philippines and a resident of 299 Aguado St. OCAMPO: Objection. what do you do whenever you visit the complainant at their apartment and she is not around? PROSECUTOR ANTHONY PRESTOZA: Were you aware that the accused likes you? RICHARD NALUPTA: I wait for her to come back. who do you find at their apartment? PROSECUTOR ANTHONY PRESTOZA: How is she related to the complainant? RICHARD NALUPTA: Iris. Counsel is speculating. and during weekends.

RICHARD NALUPTA: At the living room. 09173237890. PROSECUTOR ANTHONY PRESTOZA: This text message purports to have been sent by the person owning this mobile number. Your Honor. if I won’t have you. please examine this text message. no one else will) . Your Honor. PROSECUTOR ANTHONY PRESTOZA: What did your fiancé say? RICHARD NALUPTA: She said: Don’t mind her. RICHARD NALUPTA: I watch the tv or listen to music. RICHARD NALUPTA: Yes. kung hindi ka magiging akin. 2007. PROSECUTOR ANTHONY PRESTOZA: So there were times that only you and the accused were in the apartment. is that right? RICHARD NALUPTA: Because I told her a few times about it. PROSECUTOR ANTHONY PRESTOZA: Why? PROSECUTOR ANTHONY PRESTOZA: You said earlier that whenever the complainant is not around during your visit. Your Honor. PROSECUTOR ANTHONY PRESTOZA: What do you tell the accused every time she flirts with you? RICHARD NALUPTA: I don’t mind her jokes. mga ganun. Your Honor. Iris was at the apartment. Your Honor. Your Honor. she says I love you jokingly. what normally transpires? PROSECUTOR ANTHONY PRESTOZA: Does your fiancé know of these instances? RICHARD NALUPTA: Yes. Witness. RICHARD NALUPTA: Because the mobile number of the accused is stored in my mobile phone. walang makikinabang sayo!€ (Richie. that is the mobile number of the accused. Do you recognize the person who owned this number? RICHARD NALUPTA: Yes. Your Honor. RICHARD NALUPTA: Because I received that text message from the accused on August 15. and tell the Court if you recognize it? RICHARD NALUPTA: Yes. She’s crazy.€ PROSECUTOR ANTHONY PRESTOZA: Mr. PROSECUTOR ANTHONY PRESTOZA: What transpires whenever you and the accused are alone in the apartment? PROSECUTOR ANTHONY PRESTOZA: Why do you recognize it? RICHARD NALUPTA: The accused flirts with me. PROSECUTOR ANTHONY PRESTOZA: Do you recall how many times these have happened? PROSECUTOR ANTHONY PRESTOZA: How do you know? RICHARD NALUPTA: Many times. PROSECUTOR ANTHONY PRESTOZA: Will you please read aloud the contents of this text message? RICHARD NALUPTA: Richie. PROSECUTOR ANTHONY PRESTOZA: What do you mean when you said she was flirting with you? RICHARD NALUPTA: She wears revealing clothes. PROSECUTOR ANTHONY PRESTOZA: And while waiting. Your Honor. Your Honor. while you were waiting for the complainant? RICHARD NALUPTA: Yes.

PROSECUTOR ANTHONY PRESTOZA: How often does she send you this kind of text messages? RICHARD NALUPTA: Almost everyday. COURT: Cross? ATTY. for the record. I waited for the doctor to come out. Merin as your friend? . Whoever tries to steal you from me will die. what did he tell you? PROSECUTOR ANTHONY PRESTOZA: No further questions. Nalupta. Mamamatay ang kahit sinong aagaw sayo. ATTY. ANALITA OCAMPO: Would you consider Ms. Merin? RICHARD NALUPTA: I have known her ever since I began courting my fiance since both of them live in the same apartment. previously marked as Exhibit C has been identified by the witness.) PROSECUTOR ANTHONY PRESTOZA: What did you do afterwards? RICHARD NALUPTA: I called for an ambulance. COURT: Mark it. We rushed her to the hospital. RICHARD NALUPTA: No. PROSECUTOR ANTHONY PRESTOZA: What did you do when you learned of the incident? RICHARD NALUPTA: I rushed to her. RICHARD NALUPTA: About four hours.PROSECUTOR ANTHONY PRESTOZA: Mr. she tried to flirt with you. ( extra sweetness ) RICHARD NALUPTA: She was with the accused. ATTY. Nalupta. Thats about four years ago. Your Honor. Richie. OCAMPO: Yes. RICHARD NALUPTA: The doctor said my fiance was poisoned. She was already lying on the ground. Your Honor CROSS EXAMINATION OF RICHARD NALUPTA (BOYFRIEND OF THE COMPLAINANT /PROSECUTION WITNESS) BY ATTY. Witness. Richie. kindly read the next text message. ANALITA OCAMPO: How long have you known Ms. these text messages appearing on the screen of the mobile phone of Mr. you have testified that whenever you and Ms. ANALITA OCAMPO: What made you say that? PROSECUTOR ANTHONY PRESTOZA: Who was with the victim when the incident happened? RICHARD NALUPTA: Well. Merin are alone in the apartment.€ (You’re mine. ATTY. PROSECUTOR ANTHONY PRESTOZA: This document is the printed copy of the text messages contained in the mobile phone of Mr. Your Honor. ANALITA OCAMPO (DEFENSE COUNSEL) RICHARD NALUPTA: I was entertaining our friends. RICHARD NALUPTA: Akin ka lang. We would like to request that it be marked as Exhibit C-1. Your Honor. I feel she made some advances. Is that right? PROSECUTOR ANTHONY PRESTOZA: Were you near the victim? RICHARD NALUPTA: Yes. I was about 8 meters away from her. ATTY. PROSECUTOR ANTHONY PRESTOZA: How long did you stay with her at the hospital? PROSECUTOR ANTHONY PRESTOZA: Your Honor. Witness. PROSECUTOR ANTHONY PRESTOZA: What were you doing during the engagement party? PROSECUTOR ANTHONY PRESTOZA: When the doctor came out. ANALITA OCAMPO: Mr.

will testify on the findings in the medico-legal report prepared by him to prove the following: (i) that the effective cause of the complainants condition is chemical poisoning. COURT: Proceed. emergency physician and a resident of Robinsons Tower. ATTY. does the complainant use your mobile phone in sending text messages to her friends? COURT: Your witness. where did you finish your medical degree? COURT: Re-direct? PROSECUTOR PRESTOZA: No. Padre Faura St. Gascon. Juan Paolo Gascon. Manila. ANALITA OCAMPO: So. JUAN PAOLO GASCON: Emilio Aguinaldo College. Witness. ATTY. ANALITA OCAMPO: Mr. COURT: Call your witness. ANALITA OCAMPO: You also testified that Ms. JUAN PAOLO GASCON (Expert Witness) BY PROSECUTOR AYN SARSABA (Prosecution Counsel) PROSECUTOR AYN SARSABA: Im calling on Dr. Merin sent you threatening text messages. DR. United Nations Avenue. is it possible that Ms. But Your Honor Im really sure she was the one who sent me those messages. all the truth and nothing but the truth in this case? ATTY. Merinâs phone has also been borrowed by someone else and it was not her who sent you those text messages? COURT: Please state your name and other personal circumstances. Juan Paolo Gascon. sometimes€ ATTY. 28 years of age. RICHARD NALUPTA: I am sure Your Honor because I am familiar with the way she constructs her messages. Juan Paolo Gascon. (ii) that the dose taken by the complainant is necessarily fatal. What is you proof that it was indeed my client who sent you those messages? DR. Merin treats you well and with extra sweetness is because she considers you as a close friend since you are the fiance of her best friend? RICHARD NALUPTA: Yes DIRECT EXAMINATION OF DR. Witness.RICHARD NALUPTA: Ummm…. ATTY. Your Honor. RICHARD NALUPTA: Yes. PROSECUTOR AYN SARSABA: This witness. ANALITA OCAMPO: Mr. single. Your Honor? RICHARD NALUPTA: Yes its possible. Yes. and (iii) that the possible source of the cyanide poison is the grape fruit juice prepared by the accused. JUAN PAOLO GASCON :Yes. JUAN PAOLO GASCON Dr. Your Honor. Your Honor. May we proceed. ANALITA OCAMPO: How about you? Are there times when you borrow the complainants cellular phone? RICHARD NALUPTA: Yes. INTERPRETER: Do you swear to tell the truth. ATTY. is it possible that the reason why Ms. PROSECUTOR AYN SARSABA: When did you graduate? . Dr. there are times I use her phone. Dr. Ermita.. We will call on our last witness. ANALITA OCAMPO: No further questions. Manila. PROSECUTOR AYN SARSABA: You declared that you are a doctor of medicine. DR.

PROSECUTOR AYN SARSABA: What is your present designation? PROSECUTOR AYN SARSABA: Do you recall when was that doctor? About what time? DR. JUAN PAOLO GASCON: 1994? PROSECUTOR AYN SARSABA: Are you a licensed physician? January in Florida. DR. JUAN PAOLO GASCON: Yes. JUAN PAOLO GASCON: Im presently connected with the Philippine General Hospital located in Taft. Barry Rumack and Dr. DR. around two hundred (200) cases. JUAN PAOLO GASCON: We made sure that the neurologic and cardiovascular status has normalized and acidosis and other metabolic abnormalities have resolved before we discharged her. have you attended seminars and undertaken training in connection with the practice of medicine? When and where? PROSECUTOR AYN SARSABA: Do you recall how many days was she confined to the hospital? DR. To name a few: One of the international medical conferences I’ve attended was in Switzerland last October 2007 called Poisoning and Drug Overdose by Dr. I have also been invited as a guest speaker to give special lectures on modern medical toxicology and the medico-legal aspect of poisoning. mostly on medico legal cases. medical malpractice cases and industrial and vehicular accidents. DR. PROSECUTOR AYN SARSABA: Since you became a licensed physician. JUAN PAOLO GASCON: I have been employed there since 1998. PROSECUTOR AYN SARSABA: Since when have you been employed in that hospital? PROSECUTOR AYN SARSABA: Do you recall having attended on one Catherine Jane Manarang at the Philippine General Hospital? DR. Allan Hall who were internationally recognized experts in internal medicine. JUAN PAOLO GASCON: Yes. JUAN PAOLO GASCON: She was confined for one week. DR. DR. JUAN PAOLO GASCON: For the past 5 years. JUAN PAOLO GASCON: Im presently an emergency physician in said institution. 2007. Manila. JUAN PAOLO GASCON: Yes. I have attended several training seminars on emergency medicine held here and abroad. USA entitled Emergency Medicine: Practicing According to the Evidence. JUAN PAOLO GASCON: About 6:30 in the evening of October 17. Another would be the one held just last PROSECUTOR AYN SARSABA: Why was she confined that long? DR. . PROSECUTOR AYN SARSABA: How many medico legal cases so far have you testified? What kind of medico legal cases have you testified? PROSECUTOR AYN SARSABA: Where are you presently connected? DR.DR. Mostly homicide and murder cases involving food and chemical poisoning. JUAN PAOLO GASCON: Yes. In fact. JUAN PAOLO GASCON: in 1995. PROSECUTOR AYN SARSABA: Have you testified as a Medical expert in cases before courts of justice? PROSECUTOR AYN SARSABA: When did you pass the doctors board examination? DR. DR.

do you know whose signature is this doctor? DR. that the signature appearing in Exhibit D be marked as Exhibit D-1. is in a healthy state of mind? DR. PROSECUTOR AYN SARSABA: Did you find any neurologic complications in said follow-up? DR. constant monitoring for any sign of deterioration and further evaluation. PROSECUTOR AYN SARSABA: For the record. did you continue attending on her? A: Yes. PROSECUTOR AYN SARSABA: So Doctor.8 degree Celsius. Her vital signs then were: Blood pressure 80/50 mmHg. JUAN PAOLO GASCON: Yes. PROSECUTOR AYN SARSABA: Could you please explain this finding in more simple terms for an ordinary person to understand? DR. PROSECUTOR AYN SARSABA: Why? DR. it is poisonous. PROSECUTOR AYN SARSABA: There is a signature above the typewritten name Dr. did you require her to still see you for further medications? A: Yes. COURT: Mark it. JUAN PAOLO GASCON: I advised the patient to have a follow-up within 7 to 10 days after discharge to reevaluate and monitor for onset of delayed neurologic manifestations. Juan Paolo Gascon. It revealed the presence of trace amounts of cyanide in the blood. PROSECUTOR AYN SARSABA: Why is the condition of Catherine Jane Manarang attributable to poisoning rather than to disease or some natural cause? Were tests conducted confirming the existence of poisoning? DR. the witness has identified the document previously marked as Exhibit D as the Medico Legal Report issued by Dr. JUAN PAOLO GASCON: The patient came in the emergency room stretcherborne. JUAN PAOLO GASCON: Yes. PROSECUTOR AYN SARSABA: I respectfully request Your Honor. (Witness reading a portion of the medico legal report) DR. Respiratory Rate of 12 cycles per minute and temperature of 37. Juan Paolo Gascon. PROSECUTOR AYN SARSABA: Doctor. PROSECUTOR AYN SARSABA: Do you know what could have caused this kind of condition? DR. Juan Paolo Gascon.PROSECUTOR AYN SARSABA: While in the hospital. and since cyanide is not normally found in our blood and considering its chemical nature. complainant herein. warranting an immediate medical intervention. Your Honor. JUAN PAOLO GASCON: Yes. unconscious and in respiratory distress. JUAN PAOLO GASCON: My diagnosis at that time was there was chemical poisoning. JUAN PAOLO GASCON: None. we are assured that the patient. JUAN PAOLO GASCON: It is my signature. Q: After her discharge. PROSECUTOR AYN SARSABA: Did the patient see you for a follow-up Doctor? DR. JUAN PAOLO GASCON: We did Toxin Screening with the patient’s blood. PROSECUTOR AYN SARSABA: So you are saying that the actual or effective cause of the condition of the patient s . PROSECUTOR AYN SARSABA: Attached to the record of the case is a Medico Legal Report issued by one Dr. please read this particular entry. or in a very critical condition. Cardiac rate of 50 beats per minute. is this the one you are referring to? (Exhibit D) DR. JUAN PAOLO GASCON: The patient clearly was in an unstable condition. Patients skin was flushed.

which is harmful to the body or deadly to humans. loss of consciousness. from the onset of symptoms to the time of consultation. Doctor? Was it Miss Merin? ATTY. Court: Sustained. JUAN PAOLO GASCON: An analysis of the patients blood would tell us the amount or level of cyanide in the blood. PROSECUTOR AYN SARSABA: Now. said patient mentioned to me that she also drank grape fruit juice. the question is leading! PROSECUTOR AYN SARSABA: Who was the informant of the patient in this case? DR. PROSECUTOR AYN SARSABA: Did the symptoms which appear resemble the typical symptoms of poisoning by the alleged poison? DR. you mentioned about an informant. JUAN PAOLO GASCON: Chemical poison. vomiting. Doctor? DR. and during the party. Several scientific studies have shown that the toxic threshold dose is 50 to 100mg of cyanide in the human body. possible sources of cyanide could be any of the food or beverage the patient had ingested on the day of the incident. JUAN PAOLO GASCON: We fill out a form called History and Physical Examination. JUAN PAOLO GASCON: Fatal dose is the smallest dose known to cause death: not the smallest amount which will certainly cause death. Reason for the Consult or Chief Complaint. nausea. JUAN PAOLO GASCON: As previously stated. PROSECUTOR AYN SARSABA: Doctor.5 mg/dL cyanide content. PROSECUTOR AYN SARSABA: Is that all. TAPIRE: Objection. what could be a possible source of cyanide in this case? DR. PROSECUTOR AYN SARSABA: What are you trying to tell us Doctor? . I can extrapolate that the amount ingested by the patient is lethal or fatal. she drank coke zero. JUAN PAOLO GASCON: It was Miss Iris Merin. was the dose taken by the victim necessarily fatal? DR. PROSECUTOR AYN SARSABA: History? What do you mean by that Doctor? DR. flushed skin. Relevant here is the History of Present Illness. It is possible that the grape fruit juice could be the source of cyanide considering that she ingested the same 3 hours before the onset of symptoms.DR. PROSECUTOR AYN SARSABA: Now. the History of Present Illness and the Past Medical History. generalized body weakness. PROSECUTOR AYN SARSABA: What is the minimum lethal dose of cyanide? DR. This refers to the events and activities of the patient which transpired prior to the consultation. Contained here are the General Data. JUAN PAOLO GASCON: Yes. TAPIRE: Objection. the patient would have died. The patients blood was found to have 1. Your Honor. JUAN PAOLO GASCON: Based on the history given to me by the informant when the patient was brought to the ER. green tea Frappuccino. Based from this definitive finding. my question to you is: Is it possible Doctor that a grape fruit juice can be a source of the cyanide poison? ATTY. If no prompt intervention was done. The symptoms of cyanide poisoning are headache. the question is leading. during the confinement of the patient in the hospital for one week. PROSECUTOR AYN SARSABA: Would you please tell the Court what it was exactly that Miss Merin told you? DR. the food intake of the patient consisted of tuna sandwich. JUAN PAOLO GASCON: Actually. fresh green salad. JUAN PAOLO GASCON: The informant told me that during their coffee break on the day of the incident. PROSECUTOR AYN SARSABA: In your opinion. the symptoms of the patient would eventually lead to cardio-pulmonary arrest (death). DR. and unstable vital signs all of which are present in this case. Who was the informant of the patient in this case.

JUAN PAOLO GASCON: It seems that the rodenticide has been intentionally mixed into the grape fruit juice. when does ingestion of the cyanide poison cause the onset of symptoms of cyanide poisoning? DR. am I right? DR. JUAN PAOLO GASCON (EXPERT WITNESS) BY ATTY. PAULETTE TAPIRE: The patient-complainant also testified that she drank two glasses of the alleged source of the poison the grape fruit juice at around 2:45 pm and the onset of the symptoms of cyanide poisoning was about 6:00 pm. It also illustrates that the grape fruit juice is hence contaminated with cyanide. the more severe the symptoms will be. loss of consciousness. does it not mean that the condition of the patient can not be attributed to cyanide poisoning but to some other cause? DR. PROSECUTOR AYN SARSABA: Doctor. It also shows that rodenticide has 50% cyanide concentration. PAULETTE TAPIRE: Doctor. ATTY. JUAN PAOLO GASCON: The severity of the symptoms may serve as an indication of how lethal the dose of cyanide is. COURT: Cross? ATTY. Thus. JUAN PAOLO GASCON: Yes. PAULETTE TAPIRE (DEFENSE COUNSEL) ATTY. found in the apartment of the complainant and accused. the initial signs and symptoms can resemble those of anxiety or hyperventilation syndrome. This is the Toxicology Report from the NBI on the results of their chemical analyses of the sample taken from the grape fruit juice in the pitcher and of the sample taken from the rodenticide or rat killer. hence. dont you think there is an inconsistency of the duration of ingestion and onset of symptoms between the patients actual case and the established scientific findings of cyanide poisoning? With this. That is possible. Or that the effect of poisons in the body is usually proportional to the dose taken. PAULETTE TAPIRE: Doctor. PROSECUTOR AYN SARSABA: Doctor. PAULETTE TAPIRE: If thats the case. JUAN PAOLO GASCON: Yes.DR. Rat-A-Rest. PROSECUTOR AYN SARSABA: No more questions. Your Honor. JUAN PAOLO GASCON: Patients who ingest potentially fatal amounts may not develop life-threatening symptomatology for up to 1 to 2 hours following exposure. CROSS EXAMINATION OF DR. ATTY. PROSECUTOR AYN SARSABA: As an expert. Late signs of poisoning are nausea. am I right? A: Yes. Your Honor. The bigger the dose. do you have any other field of expertise? DR. you have testified that you also specialize in Toxicology specifically Poisoning and Drug Overdose. ATTY. I specialize in Forensic Medicine and Toxicology specifically Poisoning and Drug Overdose. have you formed an opinion? DR. Q: But you also said that symptoms of cyanide poisoning are expected to develop 1 to 2 hours following ingestion? DR. you are an expert in that field. can you please interpret to us the findings in this report? DR. JUAN PAOLO GASCON: Yes. JUAN PAOLO GASCON: This report reveals that the sample taken from the grape fruit juice has been contaminated with rodenticide. JUAN PAOLO GASCON: Yes. TAPIRE: Yes. PAULETTE TAPIRE: Symptoms such as? DR. . I am also an expert chemist and toxicologist. PROSECUTOR AYN SARSABA: I will show you a document. JUAN PAOLO GASCON: In patients who do not experience sudden collapse. and a variety of cardiac effects. 3 hours had lapsed from the ingestion of the alleged source (grape fruit juice) before the symptoms developed. Early signs include headache. previously marked as Exhibit E. vomiting. ATTY.

ATTY. PAULETTE TAPIRE: Are you aware of the history of said patient. PAULETTE TAPIRE: And that there are other possible sources of the cyanide as well? DR. JUAN PAOLO GASCON: Yes. JUAN PAOLO GASCON: Yes. JUAN PAOLO GASCON: I can say that it is possible that the patients condition was not due to cyanide poisoning. history of the patients mental condition and history of business. is it safe to conclude. The body may acquire tolerance to some substances. ATTY.ATTY. PAULETTE TAPIRE: That the grape fruit juice is just one possible source of the cyanide poison? COURT: Re-direct? DR. Your Honor. attempted to end her life due to depression? DR. Your Honor. PAULETTE TAPIRE: By possible. ATTY. ATTY. JUAN PAOLO GASCON: Yes. marital and social failures are taken into consideration in cases of poisoning. right? ATTY. JUAN PAOLO GASCON: Yes. DR. is said fact relevant to the determination of the cause of the symptoms? DR. rhodamine activity is too slow to prevent serious toxicity or death. PAULETTE TAPIRE: In your opinion. that the cyanide poison may have come from another source considering that for that day. The availability of sulfur constitutes the rate limiting factor in natural cyanide detoxification. PAULETTE TAPIRE: That she has a history of one previous suicidal attempt one year from the date of the incident? DR. JUAN PAOLO GASCON: Some persons possess different levels of sensitivity to certain substances. PAULETTE TAPIRE: Doctor. Another would be: The body has a natural defense against cyanide exposure in the form of an endogenous enzyme. ATTY. namely. PAULETTE TAPIRE: So. rhodamine. PAULETTE TAPIRE: Are you sure? DR. Doctor. JUAN PAOLO GASCON: Yes. In the absence of exogenous source of sulfur. Ma’am. JUAN PAOLO GASCON: Yes. PAULETTE TAPIRE: No further questions. History of any previous suicidal attempts. Your Honor RE-DIRECT EXAMINATION OF DR. is it possible that the onset of symptoms for cyanide poisoning varies for each person? Is it possible that said symptoms may appear beyond the normal 1-2 hour duration? DR. you mean¦? DR. JUAN PAOLO GASCON(EXPERT WITNESS) BY PROSECUTOR SARSABA (PROSECUTION COUNSEL) PROSECUTOR SARSABA: Doctor. A: Probable or potential source of the poison. JUAN PAOLO GASCON: That is possible. PROSECUTOR SARSABA: Will you explain to us how that is possible? DR. forming the much less toxic ion thiocyanate. that is possible. JUAN PAOLO GASCON: Yes. ATTY. This enzyme catalyzes cyanide complexing with sulfur. JUAN PAOLO GASCON: Yes. PROSECUTOR SARSABA: Yes. ATTY. the patients food intake comprised of different food and beverages? DR. that she had at one time in the past. about the source of the poison. . ATTY. PAULETTE TAPIRE: Is it safe to conclude then that it is possible that the poisoning is attributable to suicide? ATTY. you only said possible sources.

Exhibit B is the pitcher from which a sample was taken and subjected to chemical analysis for the purpose of proving the fact that the source of poison was the grapefruit juice prepared by the accused contained in the pitcher. the serious toxic effects of cyanide will be diminished. COURT: How do you intend to submit your formal offer? PROSECUTOR SARSABA: We can now offer our evidence. the cyanide detoxification in the body is hastened. Your Honor. we are now resting the case for the prosecution. DR. we admit the existence and . Exhibit C-1 consists of printed copies of the text messages to corroborate to the fact that the accused had been sending several text messages to the complainants boyfriend to manifest her obsession.PROSECUTOR SARSABA: Could you explain to the Court what you mean by that Doctor? Exhibit A-3 is the stipulation regarding the pest control measures to prove that the lessor undertakes to conduct the quarterly pest control measures. there was a one-hour delay of appearance of symptoms because as confirmed in her lab tests. you may step down. Juan Paolo Gascon to be a part of his testimony that he was the attending physician of the complainant. Your Honor. Exhibit C consists of text messages to prove that the accused nurtured feelings for the complainants boyfriend. COURT: Any comment? ATTY. COURT: Re-cross? Exhibit D is the Medico Legal Report issued by Dr. Your Honor. the food intake of the patient may possibly contribute to such effect. Lastly. there are some cases in which the signs and symptoms of cyanide poisoning in a patient may be delayed and appear beyond the normal duration. OCAMPO: As to Exhibits A. PROSECUTOR SARSABA: Your Honor. PROSECUTOR SARSABA: No further questions. A-1. her body produces abnormal amounts of sulfur and as I’ve mentioned earlier. Exhibit F is the Box of Rat Killer to prove the source of the poison which was bought by the accused. Exhibit E is the Toxicology Report of the National Bureau of Investigation to prove the chemical analysis of the sample taken from the pitcher for qualitative and quantitative determination of the poison. when there is more sulfur in the body. Exhibit A-1 and A-2 are the signatures of Catherine Jane Manarang as lessee and Rhandell Matuloy as lessor to prove that these two persons were the contracting parties to the lease agreement. (i) that the effective cause of the complainants condition is chemical poisoning. Exhibit D-1 is the signature of Dr. JUAN PAOLO GASCON: Even though the normal duration is 1 to 2 hours. Formal Offer of Evidence by the Prosecution (ii) that the dose taken by the complainant is necessarily fatal. Witness. COURT: Proceed PROSECUTOR SARSABA: Exhibit A is the Contract of Lease being offered to prove that there is a stipulation on the quarterly conduct of pest control measures by the lessor. TAPIRE: No re-cross. A-2 and A-3 we admit the existence and authenticity. Your Honor. As to Exhibits C and C-1. Juan Paolo Gascon to prove the following: ATTY. In the case of the patient Miss Manarang. and (iii) that the possible source of cyanide poison is the grapefruit juice prepared by the accused. we admit its existence but not its purpose. COURT: Mr. we can only admit as to the existence of the text messages but not its authenticity. As to Exhibit B. As to Exhibit D and D-1. thus.

I finished my Master of Psychiatry degree at the University of Melbourne in 1998.LEIRA TARUC: In 1995. Quaipo. Latin Honors Your Honor. HELEN PAULETTE TAPIRE: Do you know the complainant in this case? DR. Your Honor. . HELEN PAULETTE TAPIRE: When were you admitted to the practice of medicine? ATTY. ATTY.LEIRA TARUC: Yes. As to Exhibit F. ATTY. treatment and prevention of mental and emotional illness and behavioral disorders of patients.authenticity.LEIRA TARUC: I graduated from the University of Santo Tomas in the year 1994. DR. INTERPRETER: Do you swear to tell the truth. and a resident of 123 Krusada St. the Court resolves to admit all the exhibits offered by the defense counsel specified in the offer.LEIRA TARUC: I listen and talk to patients about their mental. HELEN PAULETTE TAPIRE: What is the nature of your work as a psychiatrist? DR. 35 years old. the witness is presented to testify on the medical records of the complainant who underwent several counseling sessions under her supervision and to prove the mental and emotional instability of the complainant. Your Honor. HELEN PAULETTE TAPIRE: Did you graduate with honors? DR. HELEN PAULETTE TAPIRE: Why do you know her? DR.LEIRA TARUC: I am Dr. ATTY. HELEN PAULETTE TAPIRE: For the defense.LEIRA TARUC: Yes Ma’am. HELEN PAULETTE TAPIRE: How do you treat your patients? DR.LEIRA TARUC: Yes. cognitive therapy. HELEN PAULETTE TAPIRE: Your Honor.LEIRA TARUC (EXPERT WITNESS) BY ATTY. Your Honor. ATTY. HELEN PAULETTE TAPIRE (DEFENSE COUNSEL) ATTY. HELEN PAULETTE TAPIRE: From what university or college did you graduate and when? COURT: Acting on the formal offer of exhibits of the prosecutor and comments thereon by the defense counsel. Your Honor. Manila. May we proceed. a licensed psychiatrist at the Psychiatry Department. behavioral therapy or psychological counseling depending on the patients needs. DEFENSE DIRECT EXAMINATION OF DR. ATTY. Leira Leonor Taruc.LEIRA TARUC: As a psychiatrist I deal with the diagnosis. COURT: Please state your name and other personal circumstances. all the truth and nothing but the truth in this case? ATTY.LEIRA TARUC: Yes.LEIRA TARUC: For almost 10 years. As to Exhibit E. Your Honor? COURT: Proceed. we admit its authenticity and genuineness. DR. Your Honor. ATTY. we are ready to present our first witness. single. HELEN PAULETTE TAPIRE: Do you have any post-graduate degree? COURT: Proceed. DR. DR. Your Honor. Medical Center Manila. ATTY. emotional or behavioral problems and assess the status of these disorders. ATTY. HELEN PAULETTE TAPIRE: Since when have you been practicing as a psychiatrist? DR. I also prescribe medications. we admit its existence but not its purpose.

Your Honor. 2006. and migraines. without psychotic features. ATTY.LEIRA TARUC: At first. ATTY.LEIRA TARUC: I conducted physical examinations. HELEN PAULETTE TAPIRE: Will you explain to this Court what that condition meant? DR. particularly her parents. HELEN PAULETTE TAPIRE: What made you conclude that the patient was suffering from this condition? . ATTY. based on our conversations. HELEN PAULETTE TAPIRE: Was the consultation out of her own volition? DR. hypertension.LEIRA TARUC: She consulted me about her condition.LEIRA TARUC: No more. ATTY. ATTY. the only traumatic event which caused the depression was the terrible accident and death of her parents. as a result of a single psychological trauma. ATTY.LEIRA TARUC: August 16. But when she began talking about her family. HELEN PAULETTE TAPIRE: What did you notice about the complainant while she was talking to you? DR. her family. insomnia. HELEN PAULETTE TAPIRE: As to her emotional condition? DR. She blamed herself for the death of her parents. she began to sob.LEIRA TARUC: No. ATTY. ATTY.LEIRA TARUC: The patient from suffered from single episode depression. HELEN PAULETTE TAPIRE: Who else did you talk to about her emotional condition? DR. She was advised by her friend.LEIRA TARUC: Yes. ATTY. what did you conclude about the complainants condition? DR. the one who advised the patient to seek help. HELEN PAULETTE TAPIRE: When was this? DR. from the examinations and observations. ATTY. and other personal relationships. I just listened to whatever she said. HELEN PAULETTE TAPIRE: Doctor. HELEN PAULETTE TAPIRE: What matters were revealed to you by the complainant in the course of the consultation? DR.DR. I asked her to tell something about her. what procedures or tests did you conduct on the complainant during the consultation? DR. While she was talking.LEIRA TARUC: I spoke to her friend.LEIRA TARUC: Single episode depression or SED is a type of major depression that occurs once. ATTY. ATTY.LEIRA TARUC: She was my patient at the Psychiatry Department of Medical Center Manila. I observed her demeanor. ATTY. This was part of the analysis of the patients condition. the patient was apparently normal. HELEN PAULETTE TAPIRE: Did you talk to anyone else regarding the patients emotional condition? DR. and her gestures. and then she cried. HELEN PAULETTE TAPIRE: Any other tests that you conducted on the patient? DR. HELEN PAULETTE TAPIRE: For what reason did she come to your clinic? DR.LEIRA TARUC: The physical examinations revealed sleeping apnea.LEIRA TARUC: The patient is suffering from major depression. Her hands were trembling. Your Honor. HELEN PAULETTE TAPIRE: Doctor. the way she spoke. her work. In the case of the patient.

loss of appetite. HELEN PAULETTE TAPIRE: And the counseling sessions were at what intervals? ATTY. HELEN PAULETTE TAPIRE For the record. In the case of the patient. Your Honor. ATTY. I have made a psychiatric assessment on the medical findings. Your Honor. Your Honor. I talk to her about what happened to her during the past week. or may not lead to weight loss. why she felt that way and how she should have viewed the negative situation. mood swings and hypnotic spells. I ask her what she felt.LEIRA TARUC: September 16.LEIRA TARUC: Yes. matched with the results of the patients physical examination.LEIRA TARUC: I conducted supportive counseling. If the patient mentioned a negative event. Miss Witness? DR. there appears a signature.LEIRA TARUC: Yes. Your Honor. HELEN PAULETTE TAPIRE: How did you treat the patient? DR. COURT: Mark it. ATTY. Your Honor.LEIRA TARUC: Yes. Your Honor. HELEN PAULETTE TAPIRE: Does this document have any relation to the report that you have prepared? (Showing the psychiatric assessment) DR. DR. DR. HELEN PAULETTE TAPIRE: When did you discharge the complainant/ patient? ATTY. HELEN PAULETTE TAPIRE: The medical findings that you had on the complainant. DR. which may. HELEN PAULETTE TAPIRE: Were there any conditions upon the discharge of the complainant? . I prescribed anti-depressant pills. HELEN PAULETTE TAPIRE: And what methods or procedures did you use to treat the patient? ATTY.LEIRA TARUC: That is my signature. that the signature appearing in this document be marked as Exhibit 2-A.LEIRA TARUC: One month. HELEN PAULETTE TAPIRE: Did you personally prepare the said writing? DR. Your Honor.DR.LEIRA TARUC: That is the report that I have prepared. ATTY. DR. DR. HELEN PAULETTE TAPIRE: I respectfully request. Your Honor. Your Honor. which include insomnia. ATTY. ATTY. HELEN PAULETTE TAPIRE: In the last page of this document. the witness has identified this document previously marked as Exhibit 2 as the psychiatric assessment record of Catherine Jane Manarang. were these reduced into writing? DR. upon request of the complainant? ATTY. ATTY. DR.LEIRA TARUC: Supportive counseling helps ease the pain of depression and addresses the feeling of hopelessness that accompanies the depression. who ordered the discharge of the complainant? DR.LEIRA TARUC: The symptoms of SED. HELEN PAULETTE TAPIRE: Did you prescribe any medication to the patient? ATTY. HELEN PAULETTE TAPIRE: Doctor. ATTY.LEIRA TARUC: Once a week. ATTY.LEIRA TARUC: I ordered the discharge. 2006. HELEN PAULETTE TAPIRE: Will you tell this Honorable Court what supportive counseling meant? ATTY.LEIRA TARUC: The patient was admitted to the hospital as inpatient. HELEN PAULETTE TAPIRE: How long did she stay at the hospital? ATTY. Whose signature is this. Your Honor.

although she is not completely stable yet. there were no longer signs of the SED. PROSECUTOR SARSABA: Yes. Your Honor.LEIRA TARUC: No. DR. when the complainant was discharged. ATTY. HELEN PAULETTE TAPIRE: And should there be a relapse. in the case of the complainant. there is a possibility of a relapse. HELEN PAULETTE TAPIRE: Unguarded DR. Your Honor.LEIRA TARUC: There was an improvement in her condition in general.LEIRA TARUC: During our last counseling session. Your Honor. LEIRA TARUC (EXPERT WITNESS) BY PROSECUTOR AYN SARSABA (PROSECUTION COUNSEL) DR. She said she would not blame herself anymore. DR. that. Will you tell this Honorable Court why it lasted only for such period? DR. ATTY. HELEN PAULETTE TAPIRE: Doctor. you testified that you treated the complainant for single episode depression. HELEN PAULETTE TAPIRE: Did the patient comply with the condition? DR. Is that true? ATTY. She did not return to the hospital after the discharge.LEIRA TARUC: In my discharge summary. the possibility of relapse is high. Doctor. She no longer cried when I asked her about the death of her parents. I stated that although the patient is being discharged. Doctor. HELEN PAULETTE TAPIRE: What do you mean she is not completely stable yet? DR. DR. ATTY. Your Honor. HELEN PAULETTE TAPIRE: No further questions. PROSECUTOR AYN SARSABA: Doctor. Your Honor. ATTY. would another suicide be also a possibility? PROSECUTOR AYN SARSABA: The anti-depressant pills that you prescribed. Your Honor. ATTY. what was her condition? CROSS EXAMINATION OF DR. HELEN PAULETTE TAPIRE: Do you mean to say. that the patients condition may recur? PROSECUTOR AYN SARSABA: What made you conclude that the patient was emotionally stable? DR.LEIRA TARUC: Yes. ATTY. She no longer showed signs of mood swings. The anti-depressant pills which I have prescribed also worked positively on her. she is to continue treatment as an outpatient. HELEN PAULETTE TAPIRE: Do you mean to say.LEIRA TARUC: If the patient does not follow the treatment plan. COURT: Cross? DR.LEIRA TARUC: The patient responded well during our counseling sessions.LEIRA TARUC: While she manifested improvement.DR.LEIRA TARUC: Yes. ATTY. what was her condition? DR. do they have any side effects? . Your Honor.LEIRA TARUC: That is possible.LEIRA TARUC: She was emotionally stable. considering she did not return to you for further treatment? PROSECUTOR AYN SARSABA: You also testified that your relationship with the complainant lasted for one month. there is a possibility of relapse. PROSECUTOR AYN SARSABA: When you discharged the complainant.LEIRA TARUC: If unguarded.

Miss Kate Nunez. In the case of the complainant. TAPIRE: Objection. the only effect was drowsiness. ANALITA OCAMPO : Do you know the complainant? KATE NUNEZ: Yes. a relapse is highly possible. ANALITA OCAMPO : May I call on our next witness. Your Honor. DR. PROSECUTOR AYN SARSABA: No further questions. married. Your Honor. is that true? DIRECT EXAMINATION OF KATE NUNEZ –(OFFICEMATE COMPLAINANT (DEFENSE WITNESS) BY ATTY. a relapse is also possible.DR. in the case of the complainant. the question is leading.LEIRA TARUC: I cannot tell.LEIRA TARUC: If the patient is under several medications and they are not followed. all the truth and nothing but the truth in this case? PROSECUTOR AYN SARSABA: Depends on what? KATE NUNEZ: Yes Ma’am. PROSECUTOR AYN SARSABA: Would that also mean that.LEIRA TARUC: I asked the patient what she felt after taking the medication.LEIRA TARUC: It depends. We will call on our last witness. ANALITA OCAMPO DR. PROSECUTOR AYN SARSABA: How high are the chances of a relapse? DR. Manila. But the effects really vary from one person to another. ATTY. Call your last witness. Paco. is the possibility of a relapse high or low? COURT: Proceed. Your Honor. COURT: Please state your name and other personal circumstances. . INTERPRETER: Do you swear to tell the truth. Your Honor. 32 years old. COURT: Re-direct? DR. ATTY. DR. PROSECUTOR AYN SARSABA: Are there any other side effects? COURT: Sustained. OF KATE NUNEZ: I am Kate Nunez. which is a normal side effect of anti-depressants. PROSECUTOR AYN SARSABA: Was the complainant under medication when she was discharged? ATTY. COURT: Miss Witness. Your Honor.LEIRA TARUC: Other anti-depressants make a patient restless and anxious. an officemate of the complainant and a resident of 345. And if the patient does not submit to further counseling sessions when required. ATTY. ATTY. Your Honor. such relapse may not happen? ATTY. PROSECUTOR AYN SARSABA: You testified that a relapse is possible if the patient does not continue treatment after discharge. ANALITA OCAMPO DR. TAPIRE: No. Your Honor. May we proceed. ANALITA OCAMPO : Why do you know her? KATE NUNEZ: I work with her at the accounting department at Nestle Philippines.LEIRA TARUC: Yes. Your Honor. The witness is being presented to testify on the character and suicidal tendencies of the complainant. You may step down. but only for anti-depressant. Your Honor? PROSECUTOR AYN SARSABA: So in your opinion. She said she felt drowsy.LEIRA TARUC: Yes.

the witness has identified this document previously marked as Exhibit A as the printed copy of the e-mail sent by the complainant. ATTY. Your Honor. ANALITA OCAMPO : What did you do when you saw her crying? KATE NUNEZ: I asked her if something wrong happened. ANALITA OCAMPO : And what was her answer? ATTY. Two days after. ANALITA OCAMPO : What was your reaction? ATTY. ANALITA OCAMPO : What did you tell her after she said those words? ATTY. on June 22. and please tell the Court if you recognized it? KATE NUNEZ: I asked her again what happened KATE NUNEZ: That is the e-mail sent by the complainant. a loner. ATTY. ATTY. ANALITA OCAMPO : How do you know? KATE NUNEZ: Because she used her signature. I want to die€ ATTY. she was crying while staring at the mirror. did you receive an e-mail from the complainant? KATE NUNEZ: I saw her one time at the comfort room. I did not ask her anymore because I know she wouldn’t tell me anyway. ANALITA OCAMPO : Can you tell the Court what the e-mail contained? . the same incident happened in the comfort room. I learned of the complainants attempt to commit suicide. ATTY. please examine this writing. ANALITA OCAMPO : Do you remember what transpired afterwards? KATE NUNEZ: After about three days. ANALITA OCAMPO : What did you do during that second incident? KATE NUNEZ: None. ATTY. ANALITA OCAMPO : For the record. ATTY. ANALITA OCAMPO : What was that? ATTY. Your Honor. ANALITA OCAMPO : How would you describe her as an officemate? KATE NUNEZ: Yes. 2006.ATTY.€ KATE NUNEZ: About two years. Your Honor. ATTY. ANALITA OCAMPO : How long have you been officemates? A: I said. KATE NUNEZ: Yes. KATE NUNEZ: She did not say anything. ANALITA OCAMPO : Who was the sender of that e-mail? KATE NUNEZ It was Catherine. KATE NUNEZ: She is a quiet person. ATTY. Your Honor. ATTY. ATTY. you can tell me your problems. ANALITA OCAMPO : Miss Witness. was there any untoward incident which involved her? KATE NUNEZ: None sir. ANALITA OCAMPO : What was her answer? KATE NUNEZ: She said. ANALITA OCAMPO : Was there any time that you noticed something different about the complainant? KATE NUNEZ: Yes. she just stared at me. Come on. ANALITA OCAMPO : In the two years that you’ve known the complainant. ATTY. ANALITA OCAMPO : Did this kind of incident happen again? ATTY. ANALITA OCAMPO : Miss Witness. ATTY.

HELEN PAULETTE TAPIRE: Do you know her personally? DIRECT EXAMINATION OF IRIS VICTORIA MERIN (ACCUSED) BY ATTY. Your Honor? COURT: Proceed. it is respectfully requested that the signature appearing in this Exhibit 3 be marked as Exhibit 3-A. ANALITA OCAMPO : This signature appearing here. OCAMPO: No further questions. HELEN PAULETTE TAPIRE: Iris Merin. ATTY. my parents didnt deserve to die that way. please tell this Honorable Court. HELEN PAULETTE TAPIRE: Your Honor. and a resident of Unit 143 Astral Apartment Padre Faura St. her perspective of the situation cannot be relied upon. HELEN PAULETTE TAPIRE (DEFENSE COUNSEL) IRIS VICTORIA MERIN: Yes. HELEN PAULETTE TAPIRE: How are you related to her? IRIS VICTORIA MERIN: She is a childhood friend. ATTY. Your Honor. all the truth and nothing but the truth in this case? IRIS VICTORIA MERIN Yes Ma’am. COURT: Your witness. ATTY. are you the same Iris Victoria Merin who is the accused in this case? IRIS VICTORIA MERIN: Yes. 2007 at around 6pm? IRIS VICTORIA MERIN: I was at the engagement party of Catherine and Richard. HELEN PAULETTE TAPIRE: Do you know the complainant? COURT: Cross? IRIS VICTORIA MERIN: Yes. HELEN PAULETTE TAPIRE: For the defense. we are ready to present the accused. ATTY. Your Honor. I am so stupid. PROSECUTOR SARSABA: No cross. 28 years of age. I should have died with them. We work in the same company and we live in the same apartment. ANALITA OCAMPO : How sure are you that this is the same e-mail which you received from the complainant? KATE NUNEZ: Because her signature appears at the bottom of the e-mail. COURT: Please state your name and other personal circumstances. ATTY. Your Honor. your honor. COURT: Proceed. where were you on October 17. food toxicologist at the Research and Development Division Nestle Philippines. is this the signature of the complainant? KATE NUNEZ: Yes. May we proceed. ATTY. ATTY. HELEN PAULETTE TAPIRE: Miss Witness. IRIS VICTORIA MERIN Iris Victoria Uy Merin. ATTY. I want to die now€ ATTY. HELEN PAULETTE TAPIRE: Can you recall what happened during that engagement party? . ATTY. the testimony of the witness is being offered to controvert the material allegations of the information against Iris Victoria Merin and to testify that due to the complainants mental and emotional state. INTERPRETER: Do you swear to tell the truth.examination for the witness.KATE NUNEZ: It says: “Dear Kate. Your Honor. ATTY. ATTY. Manila. Ermita. OCAMPO: Your Honor. Your Honor. Your Honor. single.

COURT: Sustained. She began to lose weight. ATTY. HELEN PAULETTE TAPIRE: Before the incident happened. Sometimes she just keeps quiet and not talk to me. HELEN PAULETTE TAPIRE So could you positively say that you had no idea about what transpired on that day. HELEN PAULETTE TAPIRE: What time did you leave the house? ATTY. HELEN PAULETTE TAPIRE: When you left the house. HELEN PAULETTE TAPIRE: When did her parents die? IRIS VICTORIA MERIN: No. 2007. HELEN PAULETTE TAPIRE: Did the complainant remain that way? ATTY. IRIS VICTORIA MERIN: Around May of 2006. IRIS VICTORIA MERIN: I stayed there overnight. were you aware that the complainant suffered from a major depression? ATTY. There were times that she would just cry. HELEN PAULETTE TAPIRE: What were you drinking that time? IRIS VICTORIA MERIN: I was drinking margarita. before the incident at the engagement party happened? PROSECUTOR PRESTOZA: Objection. ATTY. ATTY. HELEN PAULETTE TAPIRE: After the death of the complainants parents. Afterwards. ATTY. I saw her holding her abdomen and vomiting. IRIS VICTORIA MERIN: I left the house 6:30 am. she was drinking Coke zero. HELEN PAULETTE TAPIRE: Would you know why? ATTY. HELEN PAULETTE TAPIRE: Miss Witness. IRIS VICTORIA MERIN: She became insomniac. ATTY. It was my coffee break then. She blamed herself for their death. particularly in the afternoon. We were in the kitchen then. HELEN PAULETTE TAPIRE: Then what happened? IRIS VICTORIA MERIN: She dropped to the ground. ATTY. She lost her consciousness.IRIS VICTORIA MERIN: I was chatting with Catherine while having a drink. IRIS VICTORIA MERIN: Because she couldnt accept the untimely death of her parents. There were nights that she couldnt sleep. ATTY. what was Catherine doing? ATTY. Your Honor. She also drank liquor more often. Your Honor. IRIS VICTORIA MERIN: Yes. what happened to the complainant? IRIS VICTORIA MERIN: She told me she would take a leave because she needed to prepare for their engagement party. October 17. HELEN PAULETTE TAPIRE: At around what time was that? IRIS VICTORIA MERIN: Yes. ATTY. Your Honor. ATTY. HELEN PAULETTE TAPIRE: Did Catherine go to work that day? ATTY. HELEN PAULETTE TAPIRE: Would you know the reason why she suffered from that depression? IRIS VICTORIA MERIN: It was around 3pm. HELEN PAULETTE TAPIRE: How long did you stay at the hospital? IRIS VICTORIA MERIN: She was still sleeping. ATTY. HELEN PAULETTE TAPIRE: Did you go to work that day? . where were you? IRIS VICTORIA MERIN: I was at the Starbucks with Catherine. She was so pale and sweaty. Ritchie called for an ambulance and then we brought her to the nearby hospital. There were also mood swings. Your Honor! The question is leading.

IRIS VICTORIA MERIN: Around July or August 2006. Your Honor. before she attempted to end her life. sometimes she suddenly kept quiet. Your Honor. I also told her to stop drinking. ATTY. COURT: Cross? PROSECUTOR PRESTOZA: Yes. She was sleeping well and was no longer drinking often. you told this Honorable Court that you work as a food toxicologist. ATTY. you have knowledge of different kinds of chemicals and food substances? IRIS VICTORIA MERIN: I was always talking to her. Your Honor. There were times I caught her crying silently. Your Honor. IRIS VICTORIA MERIN: I specialize in chemical analysis of food composition and toxicity of food contents. Your Honor. HELEN PAULETTE TAPIRE: After she sought the help of a psychiatrist. asking her how she feels. HELEN PAULETTE TAPIRE: No further questions. ATTY. IRIS VICTORIA MERIN: Yes. PROSECUTOR ANTHONY PRESTOZA: Do you think it can kill a person? IRIS VICTORIA MERIN: Depending on the amount. Your Honor. HELEN PAULETTE TAPIRE: For how long did she remain that way? IRIS VICTORIA MERIN: I think around two months. ATTY. I kept telling her not to be depressed anymore.IRIS VICTORIA MERIN: Yes. HELEN PAULETTE TAPIRE: What did you do to help her in her condition? PROSECUTOR ANTHONY PRESTOZA: So. HELEN PAULETTE TAPIRE: Did you do anything to help her? IRIS VICTORIA MERIN: Yes. ATTY. what happened? IRIS VICTORIA MERIN: She sought the help of a psychiatrist. ATTY. IRIS VICTORIA MERIN: Catherine recovered from the depression. ATTY. HELEN PAULETTE TAPIRE: No more signs of the depression were present? PROSECUTOR ANTHONY PRESTOZA: What is your specialization? PROSECUTOR ANTHONY PRESTOZA: Are you familiar with rodenticide? PROSECUTOR ANTHONY PRESTOZA: Is it poisonous? IRIS VICTORIA MERIN: Yes. how long have you been practicing this profession? IRIS VICTORIA MERIN: No. because I was afraid she’d say I think shes crazy. HELEN PAULETTE TAPIRE: Did you advise her to seek medical help? CROSS EXAMINATION OF IRIS VICTORIA MERIN (ACCUSED) BY PROSECUTOR ANTHONY PRESTOZA (PROSECUTION COUNSEL) PROSECUTOR ANTHONY PRESTOZA: In the direct examination. Your Honor. IRIS VICTORIA MERIN: 7 years. Your Honor. . ATTY. what happened? IRIS VICTORIA MERIN: Yes. HELEN PAULETTE TAPIRE: When did she attempt to commit suicide? IRIS VICTORIA MERIN: Hmm. ATTY. Your Honor. HELEN PAULETTE TAPIRE: After she committed suicide.

PROSECUTOR ANTHONY PRESTOZA: The night before Catherine was poisoned. Your Honor. what time did you wake up? IRIS VICTORIA MERIN: The usual. Your Honor. PROSECUTOR ANTHONY PRESTOZA: On the day of the incident. PROSECUTOR ANTHONY PRESTOZA: Was this the package that contained the rat killer? IRIS VICTORIA MERIN: Yes. IRIS VICTORIA MERIN: Yes. PROSECUTOR ANTHONY PRESTOZA: Do you have a rodenticide at home? IRIS VICTORIA MERIN: Yes. all the drinks and food inside the apartment were either prepared by you or Catherine? PROSECUTOR ANTHONY PRESTOZA: Were you the one who bought this? IRIS VICTORIA MERIN: Most probably. Your Honor. IRIS VICTORIA MERIN: Yes. Your Honor. well in fact our lease agreement provides that we should report any complaints we have to the lessor. Your Honor. previously marked as Exhibit F? IRIS VICTORIA MERIN: Yes. PROSECUTOR ANTHONY PRESTOZA: How long have you been staying with the complainant in the same apartment? IRIS VICTORIA MERIN: About 8 years now.PROSECUTOR ANTHONY PRESTOZA: Do you use rodenticide? IRIS VICTORIA MERIN: None IRIS VICTORIA MERIN: Yes. PROSECUTOR ANTHONY PRESTOZA: So during that time. PROSECUTOR ANTHONY PRESTOZA: Do you recognize this box of rat killer. PROSECUTOR ANTHONY PRESTOZA: Does this mean that either only you or Catherine prepares the food and drinks that may be found in the apartment. we use them for killing house rats. And sometimes if a close female relative from the province decides to stay for a while in the city. 5:30 AM. Your Honor . IRIS VICTORIA MERIN: No. I was surprised why Catherine bought rodenticide. In fact. we allow her to stay in the apartment. Your Honor. I have work. were there any other person staying with you in the apartment? IRIS VICTORIA MERIN: None sir. Your Honor. were you aware of the provision in the lease contract which said that it is the responsibility of the lessor to conduct quarterly pest control measures? IRIS VICTORIA MERIN: Yes. PROSECUTOR ANTHONY PRESTOZA: Do you have any other companion in the apartment where you and Catherine stay? PROSECUTOR ANTHONY PRESTOZA: Where were you during that time? IRIS VICTORIA MERIN: I was in the office. PROSECUTOR ANTHONY PRESTOZA: Did you wake up earlier than Catherine? IRIS VICTORIA MERIN: Yes. Except those which are ready to eat or drink. It was Catherine who bought it because she intends to clean the apartment and to eliminate the rats at home. PROSECUTOR ANTHONY PRESTOZA: Are you aware of the findings of the doctor who attended Catherine that she was poisoned around 6 hours earlier before she was brought to the Hospital? PROSECUTOR ANTHONY PRESTOZA: Miss Witness.

I’m happy for the both of them. I think so. PROSECUTOR ANTHONY PRESTOZA: Do you entertain him when he visits your place? IRIS VICTORIA MERIN: Not at all. asking her how she feels. Your Honor. PROSECUTOR ANTHONY PRESTOZA: Does he visit your apartment regularly? COURT: Proceed. TAPIRE: No. IRIS VICTORIA MERIN: Yes. (Pag overruled. counsel is speculating. PROSECUTOR ANTHONY PRESTOZA Objection. PROSECUTOR ANTHONY PRESTOZA: How did you come to know him? IRIS VICTORIA MERIN: He is the head security officer of the company where I and Catherine work. Your Honor. did you notice any grapefruit juice in the ref? IRIS VICTORIA MERIN: Yes. Your Honor. PROSECUTOR ANTHONY PRESTOZA: Did you nurture any affection towards him? PROSECUTOR ANTHONY PRESTOZA: You testified that you and the complainant were childhood friends. IRIS VICTORIA MERIN: No. COURT: Re-direct? ATTY. In fact. PROSECUTOR ANTHONY PRESTOZA: Miss Witness. OCAMPO: We can now formally offer our evidence Your Honor. Formal Offer of Evidence of Defense ATTY. PROSECUTOR ANTHONY PRESTOZA: Are you not jealous of your best friend? PROSECUTOR ANTHONY PRESTOZA: Did you not develop any ill feelings towards your best friend when you learned that she and Ritchie is getting married? IRIS VICTORIA MERIN: No.) IRIS VICTORIA MERIN: No. . Your Honor. We always have some stock of juice. Leira Taruc as part of her testimony attesting to the fact that she was the psychiatrist of the complainant at Medical Center Manila. OCAMPO: Exhibit 1 is the Summary Discharge Report to prove the complainants admission for treatment at the Medical Center Manila. Your Honor. she would not tell me how she feels because she liked keeping things to herself) (Pag sustained. PROSECUTOR ANTHONY PRESTOZA Did you like him? Exhibit 2 is the Psychiatric Assessment issued by Dr.PROSECUTOR ANTHONY PRESTOZA: During that time. Leira Taruc to prove mental and emotional condition of the complainant at the time she was admitted for psychiatric treatment. ATTY. COURT: Miss Witness. reform the question to: WHAT DID YOU DO TO HELP THE COMPLAINANT DURING THE TIME SHE WAS SUFFERING FROM DEPRESSION? Answer: I was always talking to her. Your Honor. OCAMPO: Your Honor. Exhibit 2-A is the signature by Dr. do you know the fiancé of the complainant? IRIS VICTORIA MERIN: Yes. You may step down. COURT: How do you intend to submit your formal offer? ATTY. but knowing her. PROSECUTOR ANTHONY PRESTOZA: No further questions. if she was okay or not. Your Honor. ANSWER: I was concerned about her. we are now resting the case for the defense. Your Honor. Were you not concerned during the time that she suffered from depression? IRIS VICTORIA MERIN: No. I usually give the couple some privacy.

The case shall be deemed submitted for decision after the lapse of the said period. COURT: Any comment. COURT: Order. Your Honor. . COURT: Any rebuttal-evidence. Your Honor. Prosecutor Sarsaba? PROSECUTOR ANTHONY PRESTOZA: As to Exhibit 1 and 1-A. Fiscal? PROSECUTOR SARSABA: No rebuttal evidence. the Court resolves to admit all the exhibits offered by the defense counsel specified in the offer. COURT: Considering that the public prosecutor will not present rebuttal evidence. Exhibit 3-A is the printed copy of the electronic signature of the complainant to prove the authorship of the electronic mails sent by her. As to Exhibit 2 and 2-A. even without the said memorandum. we can only admit the existence but not the authenticity and truthfulness Your Honor. Court: Acting on the formal offer of exhibits of the defense counsel and comments thereon by the public prosecutor. we can admit its existence and authenticity.Exhibit 3 consists of printed copies of the electronic mails sent by the complainant to witness Kate Nunez to prove the mental and emotional instability of the complainant and her suicidal tendencies. the court gives the parties 30 days from today within which to file their respective memoranda.