REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

NATIONAL CAPITAL REGION
QUEZON CITY, BRANCH CIV
ELIZABETH SCHUYLER HAMILTON,
Civil Case No. 15-56789-CIV
Plaintiffs,

- versus
SEPARATION

For: PETITION FOR LEGAL

ALEXANDER HAMILTON
Defendants.
x---------------------------------------------x
JUDICIAL AFFIDAVIT
OF
NENENG PISTASYO

I.

PRELIMINARY INFORMATION.

A. NAME AND OTHER PERSONAL CIRCUMSTANCES

OF THE WITNESS.

Name
Age

:
:

NENENG PISTASYO
SIXTY-SEVEN (67) YEARS OLD

Address
:
Block 3 Lot 23 Atis Street, Fairview,
Quezon City, Metro Manila
Occupation :
and Tagalog.

Retiree Language

English

B. LAWYER WHO CONDUCTED OR SUPERVISED THE

EXAMINATION OF THE WITNESS.

Page 1 of 9

Name

YMIL RAJIV MATBA

Address
:
Aaron Burr Law Officers,
23rd floor, UP Town Center, Diliman, Quezon City

Place of Examination:
Aaron Burr Law Officers, 23rd
floor, UP Town Center, Diliman, Quezon City

II.

OFFER.

The testimony of the witness NENENG PISTASYO is being

offered to prove the:
1.

Existence of an amorous affair of Defendant,

Alexander Hamilton, during the existence of the valid
marriage between the Plaintiff and the Respondent

2.

Dates when Alexander met with Maria Reynolds

III.

JUDICIAL AFFIDAVIT PROPER.

I, NENEG PISTASYO, of legal age and sound mind, married,

Filipino, declare that I am fully conscious of the
consequences of the oath administered to me, and that I
might face criminal liability for false testimony or perjury, do
so declare:

1. Q Please state your name, age, residence, and

occupation of the witness.

A
I, Neneng Pistasyo, Filipino, sixty-five (65) years
of age, widow, and a resident of Block 3 Lot 23 Atis Street,
Fairview, Quezon City, Metro Manila, Retiree
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2. Q- Why are you here now?

A To give a sworn statement by way of a judicial affidavit,

the same to constitute as my direct testimony, in the abovecaptioned civil case.

3. QFor the record, please state the name and

address of the Lawyer who is now conducting or
supervising your examination and the place where
the examination is being held now?

A The legal counsel for the plaintiffs, Atty. Ymil Rajiv Matba
(Aaron Burr Law Offices) 23rd Floor, UP Town Center,
Diliman, Quezon City
4. Q In what language do you want your examination to
be conducted?

This judicial affidavit is prepared in English.

5. Q Do you undertake to answer the questions to be

asked of you, fully conscious that you will do so under
oath, and that you may face criminal liability for false
testimony or perjury?

A - Yes.

6.
Q Let us now proceed to the Complaint. Do you
know the parties in this case?
A Yes, they are my neighbors - Mr. Alexander Hamilton
and Mrs. Elizabeth Schuyler-Hamilton. Weve been neighbors
since 1995.

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7.

Do you have a close relationship with them?

ANo, weve been neighbors for so many years but I do

not maintain a close relationship with their family.

8.
Q - Can you please describe the family dynamics of
the Hamiltons since you became neighbors with them?

A They looked happy as a family. I always see them

every Sunday because we go to the same church in Palmera
Homes in our subdivision. I see the spouses play and bond
with their children in the park beside the church. But
sometime around late 2011, it seems that the relationship
has changed.

9.

Q - What are those changes that youve observed?

A - Since weve been neighbors since 1995, the entire

family, including the maid, go on a vacation every
November.
However in 2011, Mr. Hamilton stayed in their residential
home alone, instead of going with other members of the
family.
I have also observed that there is a woman, not his wife,
going in and out of their house and seemed to have a
romantic relationship with Alexander. I also see them kiss
each other torridly as the girl arrives and hold hands as they
go inside the house.
I regularly hear them refer to each other as My Dearest,
whenever Alexander meets this woman outside the house.

10.

Q-

Do you know who Maria Reynolds is?

A No.
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11. Q Would you be able to identify the woman Alexander

was kissing, if you see a picture of her?

A
Yes. (shows a picture) That is her. I cannot be
mistaken.

12.

A-

Q-

When did the affair begin?

31 October 2011

13. Q - Can you describe the relationship between

Alexander and Maria?

AYes. They seemed to be all over each other while the

rest of the family was on vacation.

14. Q -

Do you recall when this vacation occurred?

Yes. 31 Oct 2011 2 Nov 2011

15. Q Did you see the woman you identified in the

familys premises after the dates you mentioned?

A-

No. I did not

16.

Q Did you tell Mrs. Hamilton about what you saw?

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A
Only when I was asked by her counsel if I saw
anything that happened while the family was away on
vacation.

I dont like butting into other peoples personal lives.

Nothing Follows.

Quezon City, 08 November, 2016.

NENENG PISTASYO
Affiant/Witness

SUBSCRIBED and sworn to before me in Quezon

City on 08 November 2016, affiant showing his/her
competent proof of identity, to wit: Comelec VIN 123.

Notary Public

Doc. No. 111

Page No. 111
Book No. 111
Series of 2016.

Page 6 of 9

IV.
SWORN ATTESTATION OF THE LAWYER
WHO CONDUCTED OR SUPERVISED THE
EXAMINATION OF THE WITNESS.

The undersigned ATTY. YMIL RAJIV MATBA., of legal age,

married, and with law office address are Aaron Burr Law
Offices, 08 November 2016 at 23rd Floor, UP Town Center,
Diliman, Quezon City, under oath, deposes and states:

1.
He is the Legal Counsel for the plaintiffs in the aboveentitled case;

2.
He faithfully recorded or caused to be recorded
the questions he asked and the corresponding answers
that the above-named witness gave;

3.
Neither he nor any other person then present or
assisting him coached the witness regarding the latter's
answers; and

4.
He conducted the examination of the witness at his
law office located at Aaron Burr Law Offices at 23rd Floor, UP
Town Center, Diliman, Quezon City

Quezon City, 08 November, 2016.

Atty. YMIL RAJIV

MATBA
Affiant
Page 7 of 9

SUBSCRIBED and sworn to before me in Quezon

City on 08 November 2016, affiant showing his/her
competent proof of identity, to wit: SSS Member ID No.
1234.

Atty. Ymil Rjiv D Matba,

Aaron Burr Law Offices,
23rd Floor, UP Town Center,
Diliman, Quezon City
Doc. No. 112
Page No. 112
Book No. 112
Series of 2016.

Copy Furnished:
Atty. Julia Herrera-Lim
Hamilton and Associates
5th floor, Bahay ng Alumni,
University of the Philippines,
Diliman, Quezon City
EXPLANATION

A copy of this Judicial Affidavit is served on the

Court, the Counsel for the Defendant Alexander Hamilton via
LBC Express Corp./registered mail due to the great distances
of their respective addresses, due to the urgency of filing the

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same, and due to the lack of field personnel of the

undersigned counsel at this time.

YMIL RAJIV MATBA

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