Cross Examination on Romeo Esguerra

- Test the accuracy and truthfulness of the witness.

Purpose : To establish the prior inconsistency of the testimony of the witness.

1. Mr. witness you know very well the respondent, correct?

2. That Sometime on August 16, 2014, you converted the advisory classroom of the respondent
as a book storage as per instruction of your principal?
3. That as a result,
4. Mr Witness, good morning, you are the Property Custodian of Don Vicente Rama National
High School, is that correct?
5. As Property Custodian, you are in charge of for the safe custody of school supplies and other
school materials, correct?
6. You are also in charge of securing books of the school correct?
7. That being the in charge of the books you must have to see to it that books of the school are
properly placed and secured?
8. That you should have all access to the place where the books are secured?
9. That you should have all the keys to the place where the books are located?
a. If you would not have access because you dont have a key, how could you ensure that
the books are properly placed?

Continue if the answers are all in the affirmative.

10. You are familiar with your complaint against the respondent filed before this Honorable
Office?
11. So you are quite sure of all testimony in your complaint?
12. I would like you to read paragraph 6 of your complaint?
13. In this you denied that you owned the padlock but you prior admitted that you have all
access to the place where the books are properly secured.
14. You did all these, in order to cause inconvenience to the respondent in his work so he will be
forced to resign because he was so vocal of the irregularities and anomalies committed by
the school administration which would include you as property custodian?
15. Your honor I would like to manifest that there is inconsistency of the testimony of the
witness that he has all the keys of the place where the books are placed but he is denying that
he have access nor own the padlock

Purpose: To establish the lack of credibility of the testimony of the witness.

1. You mentioned in your Judicial Affidavit that you filed this instant complaint because of the
several wrongdoings committed by the respondent in connection with his profession,
correct?
2. To support as proof of the several wrongdoings committed by the accused, you mentioned
that cases of Grave Threats and Oral Defamation were filed against the respondent as well as
complaint for dishonesty and Grave misconduct which were filed before the Depeartment of
Education, correct?
3. Would you agree with me if this cases were still pending before the Court and the
Department of Education? Right?
4. Being pending cases, they are not yet resolved, correct?
5. That because they are not yet resolved, there is no final decree or order convicting the
respondent guilty of the purported wrongdoings he committed in relation to his profession?
6. That it cannot be used as an evidence or proof unless there is already a final decision of the
court and Deped respectively convicting the accused guilty of these alleged wrongdoings?