A. S.

Alviarne

A. Comparison of Handwriting

1. Proponent authenticates
Counsel: Mr. Witness how are you related with the decedent
Witness: I am his personal secretary sir.
Counsel: As his personal secretary what are your specific tasks?
Witness: I prepare vouchers, pay bills, go to different offices and agencies for
transactions and anything work related that Mr. Chan would order me to do.
Counsel: Have you seen the decedent write and sign in his lifetime?
Witness: Yes, sir.
Counsel: How is that Mr. Witness?
Witness: I am always with him whenever he signs documents. Oftentimes I
prepare the documents which he will sign.
Counsel: How many times have you witness the decedent sign?
Witness: In my 5 years service to him sir, a hundred times already.
Counsel: Are you familiar with his handwriting?
Witness: Yes, sir.
Counsel: If I will show his handwriting in this open court will you be able to
identify it?
Witness: Yes, sir.
Counsel: I am showing to you a document marked as Exhibit C. Can you
identify whose handwriting this is?
Witness: Yes, sir. It is the handwriting of Mr. Jose O. Chan, the decedent
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Counsel: I am showing to you a signature at the bottom of Exhibit C. Can you

identify whose signature is this?
Witness: Yes sir. It is the signature of Mr. Jose O. Chan, the decedent.
Counsel: No further questions your honor.

2. Present expert witness

Counsel: Mr. Witness, can you please state your name and residence.
Witness: I am Roger V. Abad. I am presently residing at Pembo, Makati City
Counsel: What is your occupation and where are you employed?
Witness: I am a handwriting analyst of VD Forensic Handwriting
Counsel: Describe briefly the nature of your work.
Witness: I analyze the physical characteristics and patterns of handwriting
comparing it with an exemplar.
Counsel: How long have you been engaged in the work you have described?
Witness: 15 years sir.
Counsel: Please state what special studies or training you undertook to qualify as
a specialist in your work.
Witness: I attended seminars, workshops, trainings and tutorials at Handwriting
Master Analysts of the Philippines, Inc. I am Certified Handwriting Master Analyst
(CMHA).
Counsel: How would someone be a CMHA?
Witness: By completing the 30 modules offered by the Handwriting Master
Analysts of the Philippines.
Counsel: Have you previously testified in courts of law as an expert on
handwriting?
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Witness: Yes, sir.

Counsel: How many times have you testified in open court?
Witness: I cannot exactly remember sir but about 30 times.
Counsel: I am handing you Exhibit C Did you had occasion to examine this
exhibit.
Witness: Yes, sir.
Counsel: I am also handing you Exhibit D. Did you had occasion to examine this
exhibit.
Witness: Yes, sir.
Counsel: For what purpose did you examine Exhibit C and D
Witness: For the purpose of knowing whether Exhibit C and D are executed by
one and the same person in connection to the probate of the will of Mr. Jose O.
Chan.
Counsel: Did you arrive at any conclusion as a result of your examination and
comparisons?
Witness: Yes sir.
Counsel: What is your conclusion?
Witness: Exhibit C which is the holographic will of the decedent is the same with
Exhibit D which is the handwriting admitted as decedents own.
Counsel: Upon what factors did you based this conclusion?
Witness: The papers used, the age of the decedent and the handwritings
themselves.
Counsel: How many points of comparison did you find?
Witness: Four, sir.
Counsel: What are these?
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Witness: The height relationship which were the same; the imposition of the
writing on the papers which were the same; the intercharacter spacing
connections and dimensions which were similar; and the design of letter s which
were also the same.
Counsel: Based upon your expertise in the field of handwriting analysis, are the
points of comparison conclusive as to identity of Exhibit C with the known
handwriting of decedent, Exhibit D.
Witness: Yes sir.
Counsel: Based upon your expertise in the field of handwriting analysis did the
decedent make the handwriting as shown in Exhibit C.
Witness: Yes sir.
Counsel: No further questions your honor.

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B. Qualifying a Forensic Pathologist as an Expert Witness

Counsel: Ms. Witness can you please state your name.

Witness: I am Dr. Minerva C. Abat.
Counsel: Are you a duly-licensed physician and surgeon>
Witness: Yes sir.
Counsel: How long have you been licensed to practice your profession?
Witness: 20 years sir.
Counsel: Are you presently engaged in the practice of your profession?
Witness: Yes sir.
Counsel: Where did you study for your medical degree?
Witness: I studied at UP College of Medicine for my medical degree.
Counsel: Will you please tell us just what the duties of a Medical Examiner III are.
Witness: A Medical Examiner III attends to emergency calls from Ilocos Norte
Provincial Police Office.
Counsel: Does the work include the performance of autopsies?
Witness: Yes sir.
Counsel: During your experience in the Medical Examiners Office, how many
autopsies have you performed?
Witness: About 30 sir.
Counsel: Are you affiliated in any way with any universities or academe?
Witness: I am a lecturer at Mariano Marcos Memorial State University, College of
Medicine.
Counsel: Do you specialize in any particular brand or field of medicine>
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Witness: I specialize in Forensic Pathology

Counsel: Would you tell us just what exactly Forensic Pathology involves?
Witness: It is branch of pathology that focuses on determining the cause of death
by examining a corpse.
Counsel: Are you a member of any specialized medical or scientific groups or
associations?
Witness: I am an active member of the Philippine Society of Pathologist.
Counsel: Will you please tell us what the Philippine Society of Pathology is?
Witness: It is one of the eight medical specialty societies recognized by the
Philippine Medical Association. It was established to promote the practice of
pathology. It prescribes standards and unify pathologist.
Counsel: What are the special requirements before certification as a diplomate by
the Philippine Society of Pathologist?
Witness: We need to take trainings with prescribed hours and pass a special
examination given by the Philippine Medical Examination.
Counsel: During your years of experience in the office of the Medical Examiner,
have you had occasion to observe many cases in which the cause of death was
multiple stab wounds.
Witness: Yes sir.
Counsel: Your Honor, pursuant to the rules on expert witness. I am tendering Dr.
Minerva C. Abat as a qualified expert witness in the field of forensic pathology.

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