COURTROOM SCRIPT: TRIAL

Support with Application for Support Pendente Lite

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EXAMINATION FOR TEAM PLAINTIFF
EXAMINATION OF PLAINTIFF – MARIBEL SANTOS (FLORA)
Judge: Infante
Counsel for the Plaintiff: Bakil
Counsel for the Defense: Jalaide
Clerk of Court: Munding
Stenographer: Classmate
Plaintiff Maribel Santos: Flora
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Clerk of Court (Munding): All Rise. Silence is hereby enjoined. Honorable Judge Mark
Infante, presiding. Let's pray.
(Prayer) Almighty God, we stand in Your Holy Presence as our Supreme Judge. We
humbly beseech You to bless and inspire us so that what we think, say and do will be in
accordance with Your will. Enlighten our minds, strengthen our spirit and fill our hearts
with fraternal love, wisdom and understanding, so that we can become effective
channels of truth, justice and peace. In our proceedings today, guide us in the path of
righteousness for the fulfillment of Your greater glory. Amen.
Judge (Infante): Court is now in session. (bangs gavel) Call the case.
Clerk of Court (Munding): For the record, Your Honor, this is Civil Case No. 191322,
entitled Maribel T. Santos, Plaintiff, versus Michael M. Santos, Defendant, for Support
with Application for Support Pendente Lite.
Judge (Infante): Appearances for plaintiff and defendant.
Counsel for Plaintiff (Bakil): Good morning, Your Honor. Atty. Reema A. Bakil,
appearing for the plaintiff, Maribel T. Santos. The plaintiff is also present, and we are
ready to proceed with the trial.
Counsel for Defendant (Jalaide): Good morning, Your Honor. Atty. Najib Jalaide,
appearing for the defendant, Michael M. Santos. The defendant is likewise present, and
we are ready to proceed.
Judge (Infante): Very well. Counsel for the plaintiff, you may now proceed with the
presentation of your evidence.
Counsel for Plaintiff (Bakil): Yes, Your Honor. We call the plaintiff, Ms. Maribel T.
Santos, to the witness stand.
Clerk of Court (Munding): May I call on the witness stand, the plaintiff, Ms. Maribel T.
Santos.
Judge (Infante): Please proceed and swear in the witness.
Clerk of Court (Munding): Please state your full name and other personal
circumstances.
Plaintiff (Flora): I am Maribel T. Santos, 35 years old, residing at Lot 24, Block 5,
Barangay Tumaga, Zamboanga City.
Clerk of Court (Munding): Please raise your right hand. Do you swear to tell the truth,
the whole truth, and nothing but the truth?
Plaintiff (Flora): I do. (Witness goes back to the stand and sits down)
Judge (Infante): You may proceed with your direct examination, Counsel.
Counsel for Plaintiff (Bakil): Thank you, Your Honor.
DIRECT EXAMINATION OF PLAINTIFF – MARIBEL SANTOS
Counsel for the Plaintiff (Bakil) to Plaintiff Maribel Santos (Flora)
Counsel for Plaintiff (Bakil): Your Honor, the plaintiff offers the testimony of Ms. Maribel
T. Santos to establish her entitlement to support pendente lite and continuing support
for herself and her minor child, Mateo T. Santos, and to identify her documentary
evidence. With the permission of the Court, may we proceed?
Judge (Infante): Yes, proceed.
Counsel for Plaintiff (Bakil): Ms. Santos, do you recall having executed a Judicial
Affidavit in connection with this case?
Plaintiff (Flora): Yes, ma’am.
Counsel for Plaintiff (Bakil): I am showing you this document marked as Exhibit F
during pre-trial. Can you tell the Court what this document is?
Plaintiff (Flora): That is my Judicial Affidavit, ma’am.
Counsel for Plaintiff (Bakil): Ms. Santos, please look at the signature appearing on page
[insert page number]. Do you recognize that signature?
Plaintiff (Flora): Yes, I do. It’s my signature.
Counsel for Plaintiff (Bakil): Your Honor, this Judicial Affidavit was marked as Exhibit F
during pre-trial. May I request that the signature affixed by the witness be marked as
Exhibit F-1.
Judge (Infante): Mark it. Proceed.
Counsel for Plaintiff (Bakil): Ms. Santos, can you confirm that the statements in your
Judicial Affidavit are true and correct to the best of your knowledge and belief?
Plaintiff (Flora): Yes, ma’am. All the statements in my Judicial Affidavit are true and
correct.
Counsel for Plaintiff (Bakil): Your Honor, we offer Exhibit F and Exhibit F-1 as the direct
testimony of Ms. Maribel Santos, the plaintiff.
Judge (Infante): Noted. Exhibit F and Exhibit F-1 are admitted and will serve as the
direct testimony of the plaintiff.
Counsel for Plaintiff (Bakil): Your Honor, at this point, the plaintiff respectfully makes a
formal offer of her documentary evidence:
 Exhibit “A” – Marriage Certificate (Annex A)
Offered to prove the fact of marriage between Plaintiff Maribel T. Santos and
Defendant Michael M. Santos.

 Exhibit “B” – Birth Certificate of Mateo (Annex B)

Offered to prove the filiation of the minor child, Mateo T. Santos.

 Exhibit “C” – Certificate of Employment of Defendant (Annex C)

Offered to prove Defendant’s employment and earning capacity.

 Exhibit “D” – Latest Payslip of Defendant (Annex D)

Offered to prove Defendant’s current income for purposes of determining
support.
  Exhibit “E” – Household Expense Receipts (Annex E), consisting of Exhibits E-1,
E-2, and E-3
Offered to prove the actual, regular, and necessary expenses incurred by the
plaintiff for the support of herself and her minor child.

 Exhibit “F” – Judicial Affidavit of the Plaintiff, and Exhibit “F-1” – her signature
Earlier identified, offered, and admitted as the direct testimony of the plaintiff;
respectfully reiterated as part of the plaintiff’s formal offer of evidence.

Judge (Infante): Any objections from the defense?

Counsel for Defendant (Jalaide): None, Your Honor.
Judge (Infante): There being no objection, Exhibits “A” to “F” are hereby admitted as
part of the plaintiff’s evidence.
Counsel for Plaintiff (Bakil): Thank you, Your Honor.
CROSS-EXAMINATION OF PLAINTIFF – MARIBEL SANTOS
Counsel for the Defendant (Jalaide) to Plaintiff Maribel Santos (Flora)
Counsel for Defendant (Jalaide): With the permission of this Honorable Court, counsel
for the defendant respectfully proceeds with the cross-examination of the witness.
Judge (Infante): Yes, proceed.
Counsel for Defendant (Jalaide): Ms. Santos, you testified you are currently
unemployed. That is correct, yes?
Plaintiff (Flora): Yes, sir. I am not formally employed.
Counsel for Defendant (Jalaide): But you also admitted you earn from online selling.
Would you agree that this income is not enough to sustain you and your child?
Plaintiff (Flora): Yes, Sir. But my income is irregular and very minimal. It helps a little,
but it is not enough to cover our basic needs.
Counsel for Defendant (Jalaide): You never sent the defendant any written demand for
support—no letters, no texts, no emails. Correct?
Plaintiff (Flora): That is correct, sir. But I verbally requested support several times. He
was fully aware I needed help and that our child needed support.
Counsel for Defendant (Jalaide): ou claim your monthly expenses reach ₱20,000, but
some of these have no receipts. How can the Court be sure these expenses are real?
Plaintiff (Flora): The receipts I submitted show part of the actual expenses. Many daily
household items, like food from small stores, do not issue receipts, but the expenses
were necessary and were really incurred.
Counsel for Defendant (Jalaide): Now, the defendant alleges you have been engaged
in online gambling. You are aware of this allegation, correct?
Plaintiff (Flora): Yes sir, I am aware but I completely deny that. My online activity is
strictly for selling crafts and handmade items. I have never engaged in gambling.
Counsel for Defendant (Jalaide): The defendant submitted a Facebook screenshot
showing what appears to be your name connected to an online game. Isn’t that proof
you were gambling?
Plaintiff (Flora): Sir, the screenshot does not show any gambling activity by me. It does
not show any transaction, bet, or participation attributed to me. My online activity is for
legitimate selling of bracelets and small accessories. Nothing more.
Counsel for Defendant (Jalaide): But how can you say the screenshot is unreliable?
Plaintiff (Flora): Your Honor, there is no transaction or proof of involvement, and simply
appearing on a social media post does not make me a participant. My online activity is
solely for selling crafts and handmade items, which is how I earn income to support
myself and my child. A mere screenshot without context or verification cannot prove
gambling.
Counsel for Defendant (Jalaide): You are telling this Court that the defendant never
supported you and your child? Not even once?
Plaintiff (Flora): Your Honor, he gave minimal amounts from time to time, but they were
irregular and not enough to cover even our basic daily needs.
Counsel for Defendant (Jalaide): The defendant claims he is financially stable and can
provide a better environment. Why should the child remain with you?
Plaintiff (Flora): Your Honor, custody is not determined by income alone. I have been
Mateo’s primary caregiver since birth. He has always lived with me. His routine,
emotional support, and daily needs are all centered around me as his mother.
Counsel for Defendant (Jalaide): Are you saying the father’s financial capability is
irrelevant?
Plaintiff (Flora): Not irrelevant, Your Honor—but insufficient. A child needs stability,
emotional care, and consistent presence. Those cannot be replaced by financial
contributions alone.
Counsel for Defendant (Jalaide): So you believe Mateo would suffer if placed under the
custody of his father?
Plaintiff (Flora): Yes, Your Honor. Removing him from the parent who has cared for him
every day would disrupt his emotional and psychological well-being.
Counsel for Defendant (Jalaide): You ask for ₱8,000 to ₱10,000 monthly support
pendente lite. Isn’t this excessive considering you also earn something from online
selling?
Plaintiff (Flora): No, Your Honor. My income is very small and inconsistent. The amount
requested is based entirely on the real, documented needs of Mateo. This support is
necessary to ensure that he continues to receive proper care while this case is pending.
Counsel for Defendant (Jalaide): No further questions, Your Honor.
JUDGE’S CLOSING REMARKS
(End of Plaintiff’s Examination)
Judge (Infante): Having heard the testimony of the witness and the examination
conducted by both the plaintiff and the defense, the Court now concludes the witness
examination for today's proceedings.
To summarize, this case pertains to Civil Case No. 191322, entitled Maribel T. Santos,
Plaintiff versus Michael M. Santos, Defendant, for support with an integrated application
for support pendente lite.
The Court has completed the examination of Ms. Maribel T. Santos, the plaintiff. She
testified that she has been the primary caregiver of the minor child, Mateo T. Santos,
and has incurred expenses for the child’s daily needs. She affirmed the authenticity of
key documents, including receipts for expenses (Exhibit E) and her Judicial Affidavit
(Exhibit F).
The defense, through cross-examination, raised questions regarding her partial income,
lack of written requests for support, the nature of some of her claimed expenses, and
allegations of involvement in online gambling. The plaintiff firmly denied any gambling
activity, explaining that her online activity is solely for selling crafts and handmade items
to support herself and her child. She also maintained that her income is insufficient,
daily care is continuous and necessary, and the support requested is reasonable and
justified to meet her child’s basic needs.
With the conclusion of this witness’s testimony and the plaintiff's initial presentation of
evidence for this hearing, the Court now sets the next hearing for December 15, 2025,
at 9:00 a.m., during which the plaintiff shall present her remaining witnesses, or the
defense may begin presenting evidence if the plaintiff has no more witnesses. Both
parties are reminded to ensure the attendance of their witnesses and the submission of
any necessary documents prior to the scheduled hearing.
If there are no further matters, this Court is now adjourned. Let the records reflect
today’s proceedings.
(Judge bangs gavel to officially adjourn the session)

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EXAMINATION FOR TEAM PLAINTIFF
 EXAMINATION OF WITNESS FOR
PLAINTIFF – KATRINA CRUZ (DELA TORRE, C.)
Judge: Infante
Counsel for the Plaintiff: Bakil
Counsel for the Defense: Jalaide
Clerk of Court: Munding
Stenographer: Classmate
Witness Katrina Cruz: Dela Torre
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Clerk of Court (Munding): All Rise. Silence is hereby enjoined. Honorable Judge Mark
Infante, presiding. Let's pray.
(Prayer) Almighty God, we stand in Your Holy Presence as our Supreme Judge. We
humbly beseech You to bless and inspire us so that what we think, say and do will be in
accordance with Your will. Enlighten our minds, strengthen our spirit and fill our hearts
with fraternal love, wisdom and understanding, so that we can become effective
channels of truth, justice and peace. In our proceedings today, guide us in the path of
righteousness for the fulfillment of Your greater glory. Amen.
Judge (Infante): Court is now in session. (bangs gavel) Call the case.
Clerk of Court (Munding): For the record, Your Honor, this is Civil Case No. 191322,
entitled Maribel T. Santos, Plaintiff, versus Michael M. Santos, Defendant, for Support
with Application for Support Pendente Lite.
Judge (Infante): Appearances for plaintiff and defendant.
Counsel for Plaintiff (Bakil): Good morning, Your Honor. Atty. Reema A. Bakil,
appearing for the plaintiff, Maribel T. Santos. We are ready to proceed with the
presentation of our next witness.
Counsel for Defendant (Jalaide): Good morning, Your Honor. Atty. Najib Jalaide,
appearing for the defendant, Michael M. Santos. We are likewise ready to proceed.
Judge (Infante): Very well. Counsel for the plaintiff, you may now proceed with the
presentation of your evidence.
Counsel for Plaintiff (Bakil): Yes, Your Honor. We call Ms. Katrina M. Cruz to the
witness stand.
Clerk of Court (Munding): May I call on the witness stand Ms. Katrina M. Cruz.
Judge (Infante): Please proceed and swear in the witness.
Clerk of Court (Munding): Please state your full name and other personal
circumstances.
Plaintiff (Dela Torre): I am Katrina M. Cruz, 38 years old, residing at Lot 26, Block 5,
Barangay Tumaga, Zamboanga City.
Clerk of Court (Munding): Please raise your right hand. Do you swear to tell the truth,
the whole truth, and nothing but the truth?
Plaintiff (Dela Torre): I do. (Witness goes back to the stand and sits down)
Judge (Infante): You may proceed with your direct examination, Counsel.
Counsel for Plaintiff (Bakil): Thank you, Your Honor.
DIRECT EXAMINATION OF WITNESS FOR
PLAINTIFF – KATRINA CRUZ
Counsel for the Plaintiff (Bakil) to Witness Katrina Cruz (Dela Torre)
Counsel for Plaintiff (Bakil): Your Honor, the plaintiff offers the testimony of Ms. Katrina
Cruz, a neighbor of the plaintiff who has personal knowledge of her care of the minor
child, Mateo T. Santos. Ms. Cruz will testify to Mrs. Santos role as the sole caregiver,
her financial struggles, and the respondent’s failure to provide regular support. With the
permission of the Court, may we proceed?
Judge (Infante): Yes, proceed.
Counsel for Plaintiff (Bakil): Ms. Cruz, do you recall having executed a Judicial Affidavit
in connection with this case?
Witness Cruz (Dela Torre): Yes, ma’am.
Counsel for Plaintiff (Bakil): I am showing you this document marked as Exhibit G
during pre-trial. Can you tell the Court what this document is?
Witness Cruz (Dela Torre): That is my Judicial Affidavit, ma’am.
Counsel for Plaintiff (Bakil): Ms. Cruz, please look at the signature appearing on page
3. Do you recognize that signature?
Witness Cruz (Dela Torre): Yes, ma’am. It’s my signature.
Counsel for Plaintiff (Bakil): Your Honor, this Judicial Affidavit was marked as Exhibit G
during pre-trial. May I request that the signature affixed by the witness be marked as
Exhibit G-1.
Judge (Infante): Mark it. Proceed.
Witness Cruz (Dela Torre): Yes, ma’am. All the statements are true and correct.
Counsel for Plaintiff (Bakil): Your Honor, we offer Exhibit G and Exhibit G-1 as the
direct testimony of Ms. Katrina Cruz.
Judge (Infante): Noted. Exhibit G and Exhibit G-1 are admitted and will serve as the
direct testimony of the witness.
Counsel for Plaintiff (Bakil): Thank you, Your Honor.
CROSS-EXAMINATION OF WITNESS FOR
PLAINTIFF – KATRINA M. CRUZ
Counsel for the Defendant (Jalaide) to Witness Katrina Cruz (Dela Torre)
Counsel for Defendant (Jalaide): With the permission of this Honorable Court, counsel
for the defendant respectfully proceeds with the cross-examination of the witness.
Judge (Infante): Proceed.
Counsel for Defendant (Jalaide): Ms. Cruz, you testified that you have been observing
Maribel taking care of Mateo since June 2024. You are not a family member, legal
guardian, or employed to monitor them, correct?
Witness Cruz (Dela Torre): That is correct, Sir. But I have personally observed Maribel
caring for Mateo every day since they began living separately.
Counsel for Defendant (Jalaide): You stated that Maribel earns income from sewing,
catering, and selling crafts. Are you suggesting that these earnings are insufficient to
support her child even partially?
Witness Cruz (Dela Torre): Yes, Sir. Her income is irregular and minimal. Mateo’s daily
needs cannot be reliably covered by her earnings alone.
Counsel for Defendant (Jalaide): Isn’t it true that Michael occasionally gave some
money or paid for certain expenses? Doesn’t this reduce the necessity for additional
support?
Witness Cruz (Dela Torre): Sir, the amounts given were minimal and irregular. They do
not provide the stability or consistency that Mateo needs for his daily care.
Counsel for Defendant (Jalaide): You claim that Maribel sometimes skips meals to
provide for Mateo. Couldn’t this situation have been avoided if she managed her
finances better?
Witness Cruz (Dela Torre): No, Sir. She budgets carefully, but her income is not
enough to meet both her and Mateo’s basic needs. Mateo still requires support from his
father.
Counsel for Defendant (Jalaide): You are not legally responsible for Mateo. How can
the Court be certain that your observations about the household and finances are
accurate?
Witness Cruz (Dela Torre): While I am not a legal guardian, I have personally observed
Maribel caring for Mateo every day, preparing meals, taking him to school, attending
medical appointments, and ensuring his daily needs are met. My statements are based
on firsthand knowledge.
Counsel for Defendant (Jalaide): You claim the requested support of ₱8,000–₱10,000
per month is reasonable. Isn’t this excessive given that she already earns some
income?
Witness Cruz (Dela Torre): No, Sir. Her income is irregular and cannot cover basic
needs. The requested support reflects the actual requirements for food, school, clothing,
and medical expenses.
Counsel for Defendant (Jalaide): Thank you, Ms. Cruz. No further questions, Your
Honor.
JUDGE’S CLOSING REMARKS
(End of Witness Cruz’s Examination)
Judge (Infante): Having heard the testimony of Ms. Katrina M. Cruz and the
examination conducted by both the plaintiff and the defense, the Court now concludes
the witness’s examination for today’s proceedings.
Ms. Cruz testified that she has personally observed Maribel T. Santos caring for her
minor child, Mateo T. Santos, on a daily basis since the separation of the parents. She
confirmed that Maribel provides consistent attention to the child’s needs, including
meals, schooling, and medical care, despite her limited and irregular income. Ms. Cruz
also testified that the respondent, Michael M. Santos, has not provided regular or
sufficient support, and that the monthly support requested by the plaintiff is necessary to
meet the child’s basic needs.
During cross-examination, Ms. Cruz’s credibility and the basis of her observations were
tested. She clarified that, while not a family member, legal guardian, or employed to
monitor the household, her testimony is based on firsthand observation of Maribel’s
caregiving and household management. She also maintained that Maribel’s irregular
income is insufficient to fully support Mateo and that the requested support is
reasonable.
With the conclusion of Ms. Cruz’s testimony, and with the plaintiff having presented
another witness in support of her claims, the Court now sets the next hearing for
December 18, 2025, at 9:00 a.m. Both parties are reminded to ensure the attendance
of their witnesses and the submission of any necessary documents prior to the
scheduled hearing.
If there are no further matters, this Court is adjourned. Let the records reflect today’s
proceedings.
(Judge bangs gavel to officially adjourn the session)
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EXAMINATION FOR TEAM DEFENDANT
EXAMINATION OF DEFENDANT – MICHAEL SANTOS (ENRIQUEZ, JM)
Judge: Infante
Counsel for the Plaintiff: Bakil
Counsel for the Defense: Jalaide
Clerk of Court: Munding
Stenographer: Classmate
Defendant Michael Santos: Enriquez, JM
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Clerk of Court (Munding): All Rise. Silence is hereby enjoined. Honorable Judge Mark
Infante, presiding. Let's pray.
(Prayer) Almighty God, we stand in Your Holy Presence as our Supreme Judge. We
humbly beseech You to bless and inspire us so that what we think, say and do will be in
accordance with Your will. Enlighten our minds, strengthen our spirit and fill our hearts
with fraternal love, wisdom and understanding, so that we can become effective
channels of truth, justice and peace. In our proceedings today, guide us in the path of
righteousness for the fulfillment of Your greater glory. Amen.
Judge (Infante): Court is now in session. (bangs gavel) Call the case.
Clerk of Court (Munding): For the record, Your Honor, this is Civil Case No. 191322,
entitled Maribel T. Santos, Plaintiff, versus Michael M. Santos, Defendant, for Support
with Application for Support Pendente Lite.
Judge (Infante): Appearances for plaintiff and defendant.
Counsel for Plaintiff (Bakil): Good morning, Your Honor. Atty. Reema A. Bakil,
appearing for the plaintiff, Maribel T. Santos. We are ready to proceed with the trial.
Counsel for Defendant (Jalaide): Good morning, Your Honor. Atty. Najib Jalaide,
appearing for the defendant, Michael M. Santos. We are likewise ready to proceed.
Judge (Infante): Very well. Counsel for defendant, you may now proceed with the
presentation of your evidence.
Counsel for Defendant (Jalaide): Yes, Your Honor. We call the defendant, Mr. Michael
Santos, to the witness stand.
Clerk of Court (Munding): May I call on the witness stand, the defendant, Mr. Michael
Santos.
Judge (Infante): Please proceed and swear in the witness.
Clerk of Court (Munding): Please state your full name and other personal
circumstances.
Plaintiff (Flora): I am Michael M. Santos, 38 years old, residing at 123 Mango Street,
Barangay Tetuan, Zamboanga City,
Clerk of Court (Munding): Please raise your right hand. Do you swear to tell the truth,
the whole truth, and nothing but the truth?
Plaintiff (Flora): I do. (Witness goes back to the stand and sits down)
Judge (Infante): You may proceed with your direct examination, Counsel.
Counsel for Defendant (Jalaide): Thank you, Your Honor.
 DIRECT EXAMINATION OF DEFENDANT – MICHAEL SANTOS
Counsel for Defendant (Jalaide) to Defendant Michael Santos (Enriquez, JM)
Counsel for Defendant (Jalaide): Your Honor, the defense offers the testimony of Mr.
Michael M. Santos, the defendant in this case, to establish his financial capacity, his
efforts to provide support for his minor child Mateo T. Santos, and his position regarding
the support requested by the plaintiff. With the permission of the Court, may we
proceed?
Judge (Infante): Yes, proceed.
Counsel for Defendant (Jalaide): Mr. Santos, do you recognize this document
previously marked as Exhibit 7 during pre-trial?
Defendant (Enriquez): Yes, Sir, I recognize it.
Counsel for Defendant (Jalaide): Did you personally execute this Judicial Affidavit?
Defendant (Enriquez): Yes, Sir, I did.
Counsel for Defendant (Jalaide): Did you sign this document yourself?
Defendant (Enriquez): Yes, Sir, I signed it personally.
Counsel for Defendant (Jalaide): Can you confirm that the statements contained in your
Judicial Affidavit are true and correct to the best of your knowledge and belief?
Defendant (Enriquez): Yes, Sir. All the statements are true and correct.
Counsel for Defendant (Jalaide): Your Honor, we offer Exhibit 7, the Judicial Affidavit of
Mr. Michael M. Santos, as his direct testimony in this case.
Judge (Infante): Noted. Exhibit 7 will serve as the direct examination of the defendant.
CROSS-EXAMINATION OF DEFENDANT – MICHAEL SANTOS
Counsel for the Plaintiff (Bakil) to Defendant (Enriquez, JM)
Counsel for Plaintiff (Bakil): With the permission of this Honorable Court, counsel for
the plaintiff respectfully proceeds with the cross-examination of the defendant.
Judge (Infante): Proceed.
Counsel for Plaintiff (Bakil): Mr. Santos, you testified that you have been providing
regular support to your son Mateo, correct?
Defendant (Enriquez): Yes, Ma’am. I provide support regularly, in cash and in kind.
Counsel for Plaintiff (Bakil): Can you confirm how much you actually provide every
month?
Defendant (Enriquez): I usually give around __________, plus payment of school fees
and some groceries.
Counsel for Plaintiff (Bakil): So, you admit that your contribution is irregular, correct?
Sometimes it’s ₱______, sometimes ₱______, and sometimes in kind?
Defendant (Enriquez): Yes, Ma’am.
Counsel for Plaintiff (Bakil): And you expect the plaintiff to manage Mateo’s daily needs
with this irregular amount, even though she has no steady income?
Defendant (Enriquez): I believe it is enough, Ma’am.
Counsel for Plaintiff (Bakil): You also stated in your answer that Maribel is unemployed
and that her online selling is income she did not disclose. Are you personally aware of
the amounts she earned from this business?
Defendant (Enriquez): Not exactly, Ma’am.
Counsel for Plaintiff (Bakil): So, your allegation about her “concealed income” is based
on assumption, not verified evidence, correct?
Defendant (Santos): I suppose.
Counsel for Plaintiff (Bakil): Now, Mr. Santos, in your Answer, you allege that the
Plaintiff has a gambling problem, including online betting and “tong-its,” correct?
Defendant (Enriquez): Yes, Ma’am.
Counsel for Plaintiff (Bakil): Can you provide the Court with any concrete evidence
showing she spent household funds on gambling?
Defendant (Enriquez): I have seen posts and heard about it, Ma’am.
Counsel for Plaintiff (Bakil): So, you base this serious allegation solely on social media
posts and hearsay, not firsthand knowledge?
Defendant (Enriquez): Yes, Ma’am.
Counsel for Plaintiff (Bakil): And yet you are asking the Court to deny her support and
grant custody of Mateo based on these unverified claims?
Defendant (Enriquez): I… believe it is true, Ma’am.
Counsel for Plaintiff (Bakil): Mr. Santos, you admit that Mateo’s daily needs are
currently being handled by the plaintiff. Correct?
Defendant (Enriquez): Yes, Ma’am, she manages those.
Counsel for Plaintiff (Bakil): And despite that, you still claim that she is unfit to receive
support?
Defendant (Enriquez): Yes, Ma’am.
Counsel for Plaintiff (Bakil): Now, regarding your counterclaim for custody, you admit
that Mateo is under seven years old, correct?
Defendant (Enriquez): Yes, Ma’am.
Counsel for Plaintiff (Bakil): And under Article 213 of the Family Code, the general rule
is that a child under seven is given to the mother, unless compelling reasons show she
is unfit, correct?
Defendant (Enriquez): Yes, Ma’am.
Counsel for Plaintiff (Bakil): So, apart from your unsubstantiated gambling claims, what
compelling reasons do you have to show that Maribel is unfit to care for Mateo?
Defendant (Enriquez): I believe she cannot manage expenses properly… and… I have
concerns about her income.
Counsel for Plaintiff (Bakil): Let’s discuss your employment. You work as a Senior
Manager, correct?
Defendant (Enriquez): Yes, Ma’am.
Counsel for Plaintiff (Bakil): How many hours per day are you physically present at
home to care for Mateo?
Defendant (Enriquez): Most of the day I am at work, Ma’am.
Counsel for Plaintiff (Bakil): So, if custody were transferred to you, who would ensure
Mateo’s meals, schooling, medical appointments, and daily supervision?
Defendant (Enriquez): I would hire someone to help, Ma’am.
Counsel for Plaintiff (Bakil): And do you agree, Mr. Santos, that routine, emotional
stability, and maternal care cannot be fully replaced by hired help, no matter how
competent?
Defendant (Santos): I… suppose.
Counsel for Plaintiff (Bakil): You also claim that Maribel’s online selling and alleged
gambling created financial strain. Yet, she has consistently provided for Mateo’s food,
schooling, clothing, and medical needs, correct?
Defendant (Enriquez): Yes, Ma’am.
Counsel for Plaintiff (Bakil): So, despite your allegations, Mateo’s welfare has not been
compromised, correct?
Defendant (Enriquez): Not entirely, Ma’am.
Counsel for Plaintiff (Bakil): Thank you, Mr. Santos. No further questions, Your Honor.
JUDGE’S CLOSING REMARKS
(End of Defendant’s Examination)
Judge (Infante): Having heard the testimony of Mr. Michael M. Santos and the
examination conducted by both the defense and the plaintiff, the Court now concludes
the defendant’s examination for today’s proceedings.
Mr. Santos testified about his financial capacity and his contributions to the support of
his minor child, Mateo T. Santos. He alleged that the plaintiff’s income from online
selling was not fully disclosed and claimed she engaged in gambling, and he also
advanced a counterclaim for custody.
During cross-examination, Mr. Santos admitted that he could not personally verify the
plaintiff’s income, that his gambling allegations were based on social media and
hearsay, and that Mateo’s daily needs are being met by the plaintiff. He also
acknowledged that Mateo is under seven years old, and under the Family Code,
custody generally favors the mother absent compelling reasons.
The Court notes that Mr. Santos’s testimony raises questions regarding the credibility of
his claims: the alleged concealment of income and gambling activities are unverified, his
contributions are irregular, and the practicality of transferring custody is questionable
given his work commitments.
With the conclusion of Mr. Santos’s testimony, the Court now sets the next hearing for
December 22, 2025, at 9:00 a.m. Both parties are reminded to ensure the attendance
of their witnesses and the submission of any necessary documents prior to the
scheduled hearing.
If there are no further matters, this Court is adjourned. Let the records reflect today’s
proceedings.
(Judge bangs gavel to officially adjourn the session)
---------------------------------------------------------------------------------------------------------------------
EXAMINATION FOR TEAM DEFENDANT
EXAMINATION OF WITNESS FOR
DEFENDANT – JEFFREY JALANI (ARIZO)
Judge: Infante
Counsel for the Plaintiff: Bakil
Counsel for the Defense: Jalaide
Clerk of Court: Munding
Stenographer: Classmate
Witness Jeffrey Jalani: Arizo
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Clerk of Court (Munding): All Rise. Silence is hereby enjoined. Honorable Judge Mark
Infante, presiding. Let's pray.
(Prayer) Almighty God, we stand in Your Holy Presence as our Supreme Judge. We
humbly beseech You to bless and inspire us so that what we think, say and do will be in
accordance with Your will. Enlighten our minds, strengthen our spirit and fill our hearts
with fraternal love, wisdom and understanding, so that we can become effective
channels of truth, justice and peace. In our proceedings today, guide us in the path of
righteousness for the fulfillment of Your greater glory. Amen.
Judge (Infante): Court is now in session. (bangs gavel) Call the case.
Clerk of Court (Munding): For the record, Your Honor, this is Civil Case No. 191322,
entitled Maribel T. Santos, Plaintiff, versus Michael M. Santos, Defendant, for Support
with Application for Support Pendente Lite.
Judge (Infante): Appearances for plaintiff and defendant.
Counsel for Plaintiff (Bakil): Good morning, Your Honor. Atty. Reema A. Bakil,
appearing for the plaintiff, Maribel T. Santos. We are ready to proceed with the trial.
Counsel for Defendant (Jalaide): Good morning, Your Honor. Atty. Najib Jalaide,
appearing for the defendant, Michael M. Santos. We are likewise ready to proceed.
Judge (Infante): Very well. Counsel for defendant, you may now proceed with the
presentation of your evidence.
Counsel for Defendant (Jalaide): Yes, Your Honor. We call Mr. Jeffrey Jalani to the
witness stand.
Clerk of Court (Munding): May I call on the witness stand, Mr. Jeffrey Jalani.
Judge (Infante): Please proceed and swear in the witness.
Clerk of Court (Munding): Please state your full name and other personal
circumstances.
Witness Jalani (Arizo): I am Jeffery Jalani, __________, residing at
________________.
Clerk of Court (Munding): Please raise your right hand. Do you swear to tell the truth,
the whole truth, and nothing but the truth?
Witness Jalani (Arizo): I do. (Witness goes back to the stand and sits down)
Judge (Infante): You may proceed with your direct examination, Counsel.
Counsel for Defendant (Jalaide): Thank you, Your Honor.
 DIRECT EXAMINATION OF DEFENDANT – MICHAEL SANTOS
Counsel for Defendant (Jalaide) to Witness Jeffrey Jalani (Arizo)
Counsel for Defendant (Jalaide): Your Honor, the defense offers the testimony of Mr.
Jeffrey Jalani, who has personal knowledge of the care and supervision of the minor
child, Mateo T. Santos. Mr. Jalani will testify regarding the plaintiff’s alleged neglect of
the child and her daily supervision, to support the defendant’s counterclaim for custody.
With the permission of the Court, may we proceed?
Judge (Infante): Yes, proceed.
Counsel for Defendant (Jalaide): Mr. Jalani, do you recognize the document previously
marked as Exhibit 6 during pre-trial?
Witness Jalani (Arizo): Yes, Sir, I recognize it.
Counsel for Defendant (Jalaide): Did you personally execute this Judicial Affidavit?
Witness Jalani (Arizo): Yes, Sir, I did.
Counsel for Defendant (Jalaide): Did you sign this document yourself?
Witness Jalani (Arizo): Yes, Sir, I signed it personally.
Counsel for Defendant (Jalaide): Can you confirm that the statements contained in your
Judicial Affidavit are true and correct to the best of your knowledge and belief?
Witness Jalani (Arizo): Yes, Sir. All the statements are true and correct.
Counsel for Defendant (Jalaide): Your Honor, we offer Exhibit 6, the Judicial Affidavit of
Mr. Jeffrey Jalani, as his direct testimony in this case.
Judge (Infante): Noted. Exhibit 6 will serve as the direct examination of the witness.
CROSS-EXAMINATION OF DEFENDANT – MICHAEL SANTOS
Counsel for the Plaintiff (Bakil) to Witness Jeffrey Jalani (Arizo)
Counsel for Plaintiff (Bakil): With the permission of this Honorable Court, counsel for the
plaintiff respectfully proceeds with the cross-examination of Mr. Jeffrey Jalani.
Judge (Infante): Proceed.
Counsel for Plaintiff (Bakil): Mr. Jalani, you testified that you “observed” Mateo being
left unattended. To be clear, you are not Mateo’s guardian, babysitter, nor daily
caretaker—correct?
Witness Jalani (Arizo): Yes, Ma’am.
Counsel for Plaintiff (Bakil): So, you do not see the child daily, nor do you witness his
routine before or after school, correct?
Witness Jalani (Arizo): That’s correct.
Counsel for Plaintiff (Bakil): Yet despite this limited exposure, you are claiming to have
identified “patterns” of neglect. But you cannot even provide the dates or times of these
alleged incidents, correct?
Witness Jalani (Arizo): I cannot give specific dates and times, Ma’am, but I am certain
of what I consistently observed over multiple occasions.
Counsel for Plaintiff (Bakil): So, your claim of “patterns” is based on vague recollection
rather than specific, documented observations, correct?
Witness Jalani (Arizo): I wouldn’t say it’s vague Ma’am, just not documented.
Counsel for Plaintiff (Bakil): Now, you mentioned concerns about alleged gambling by
the child’s mother. You never personally saw her gamble, not even once, correct?
Witness Jalani (Arizo): Yes, Ma’am, I did not witness it directly.
Counsel for Plaintiff (Bakil): And the only basis for this allegation is social media posts
and what you described as “other information”. Correct?
Witness Jalani (Arizo): Yes, Ma’am.
Counsel for Plaintiff (Bakil): Despite all your concerns, you admitted that Mateo is fed,
clothed, attends school, and that his mother provides for his daily needs, correct?
Witness Jalani (Arizo): Yes, Ma’am. She ensures he is fed, clothed, and goes to school.
Counsel for Plaintiff (Bakil): So, there is no instance, not one, where you personally
witnessed the child neglected, hungry, injured, or unsafe due to the mother, correct?
Witness Jalani (Arizo): I did not personally witness physical harm or hunger, Ma’am.
But I stand by my view that the child’s supervision has been lacking.
Counsel for Plaintiff (Bakil): Thank you, Mr. Jalani. No further questions, Your Honor.
Judge’s Closing Remarks
(End of Witness Examination)
Judge (Infante): Having heard the testimony of Mr. Jeffrey Jalani and the examination
conducted by both the plaintiff and the defendant, the Court now concludes the witness
examination for today’s proceedings.
During this session, the Defense, through counsel Atty. Jalaide, presented its final
witness, Mr. Jeffrey Jalani. Mr. Jalani’s Judicial Affidavit, marked as Exhibit 6, was
adopted as his direct testimony. Mr. Jalani provided his account of the circumstances he
personally observed regarding the supervision of the minor child, Mateo T. Santos. He
testified to recurring instances he believed reflected inadequate supervision, and he
affirmed the basis of his concerns regarding the child’s welfare.
On cross-examination, counsel for the Plaintiff challenged the extent and reliability of
those observations, emphasizing that the witness’s knowledge stemmed from
occasional encounters and secondary information, particularly on the issue of alleged
gambling. The witness acknowledged the limits of his firsthand knowledge, admitted
that the mother ensures the child’s basic needs are met, and clarified that his testimony
concerns supervision, not neglect in the form of hunger, injury, or lack of basic care.
Nonetheless, he maintained his position that the supervision of the child could be
improved based on what he observed.
With the conclusion of Mr. Jalani’s testimony, and he being the last witness presented
by the Defense, the Court now declares the presentation of evidence by the defendant
as concluded.
We will now proceed to the next phase of this case. The Court directs both parties to
simultaneously submit their respective Memoranda within fifteen (15) days from
today, or by January 3, 2026. Upon submission of these memoranda, this case shall
be deemed submitted for decision.
If there are no other matters to address, this Court is now adjourned. Let today’s
proceedings be duly recorded.
(The Judge bangs the gavel to officially adjourn the session)