CORDILLERA CAREER DEVELOPMENT COLLEGE

College of Law
Poblacion, Buyagan, La Trinidad, Benguet

POSITION PAPER FOR CONCUBINAGE

Submitted by:
HECTOR M. PALAO-AY

Submitted to:
ATTY. JOLANIE ANN C. LUSPIAN SACYAT

Republic of the Philippines

REGIONAL TRIAL COURT
FIRST JUDICIAL REGION
BAGUIO CITY
PEOPLE OF THE PHILIPPINES
Plaintiff,
CIVIL CASE No. _____
-versus-

For: CONCUBINAGE

JUAN DE LA CRUZ and JANE JUEVES

Defendant
x ------------------------------------x

POSITION PAPER FOR THE PLAINTIFF

PLAINTIFF, by counsel most respectfully submits this POSITION PAPER and
avers:
TIMELINESS
The Plaintiff thru counsel received an order from said Court dated
_____________ requiring the Undersigned Counsel to file position paper within ten (10)
days from receipt thereof or on or before _____________ hence said position paper is
filed.
STATEMENT OF THE CASE
This is an action for Concubinage commenced by the People of the Philippines
against the Defendant Juan De La Cruz and Jane Jueves before the Honorable Court.
Plaintiff claims that the defendant entered to an illicit relationship with Jane Jueves.
Both parties have presented their pieces of evidence. The case
STATEMENT OF FACTS

1. The plaintiff and accused Juan de la Cruz got married on January 1, 2006.
Plaintiff presented a marriage contract and is attached as exhibit A.
2. That at the time the herein parties entered into a contract of marriage accused
Juan de la Cruz entered to illicit relationship with Crissa de la Cruz.
3. That during one of plaintiff stay in the house after spending several days in Atok,
Benguet. Plaintiff accidentally discovered used condoms in the trash bag. The
defendant was not able to give an explanation and instead, raised his voice and
pretended to be angry.
4. That Juan de la Cruz and Crissa de la Cruz have three children namely: Jenny
de la Cruz, born January 1, 2008, Fred de la Cruz, born February 1, 2010; and
May 1, 2012.
5. That both accused know each other.
6. That both accused have children namely Febe de la Cruz born on November 4,
2014 and Milly Jueves Dela Cruz born on March 15, 2013, as proof thereof is a
copy of the birth certificate attached herewith as annex E and F.
ISSUE
Whether or not accused are guilty as charged.
ARGUMENTS AND DISCUSSIONS

PRAYER
WHEREFORE, premises considered, it is most respectfully prayed of the Honorable
Court that the concubinage suit be decided in favor of the plaintiff.
Other such reliefs that are just and equitable under the premises are likewise prayed for.
RESPECTFULLY SUBMITTED.
October 15, 2015.
JUANA DE LA SALLE
Counsel for Plaintiffs
Km.6, La Trinidad, Benguet
PTR No. 134342; 1/4/2013; La Trinidad, Benguet
Bar Roll No. A-564235; 8/15/2010
IBP Lifetime No. 68799; 8/24/2010; Baguio-Benguet
MCLE Compliance No. I 47786 series of 2012; 8/22/2012