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This document is a judicial affidavit from Jinky Talon Smith regarding a criminal case against her husband Raymond Edward Smith for falsifying public documents. In the affidavit, Jinky states that she and Raymond have two legitimate children, but that they took custody of her cousin Wilma Sarayan's newborn son Charles. Raymond later procured a falsified birth certificate claiming Charles was their biological son. Jinky confronted Raymond about the falsified document and filed a complaint against him with the Quezon City Fiscal's Office for committing the crime of falsifying public documents.

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Quinnee Vallejos
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571 views4 pages

JA Legal Form

This document is a judicial affidavit from Jinky Talon Smith regarding a criminal case against her husband Raymond Edward Smith for falsifying public documents. In the affidavit, Jinky states that she and Raymond have two legitimate children, but that they took custody of her cousin Wilma Sarayan's newborn son Charles. Raymond later procured a falsified birth certificate claiming Charles was their biological son. Jinky confronted Raymond about the falsified document and filed a complaint against him with the Quezon City Fiscal's Office for committing the crime of falsifying public documents.

Uploaded by

Quinnee Vallejos
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
You are on page 1/ 4

Republic of the Philippines

METROPOLITAN TRIAL COURT


National Capital Judicial Region
Branch XLII (42) – Quezon City

PEOPLE OF THE PHILIPPINES,


Plaintiff,

- versus – Criminal Case No. M-QZN-16-08661-R


For: FALSIFICATION OF PUBLIC
DOCUMENTS

RAYMOND EDWARD SMITH.


Accused.

X ---------------------------------------------------------------------------------------------- X

JUDICIAL AFFIDAVIT OF JINKY TALON SMITH

The examination of Ms. JINKY TALON SMITH was conducted by City


Prosecutor Eugene P. Kho at the City Prosecutor’s Office, Quezon City, Metro
Manila. Her testimony will be offered for the following the following purposes:

OFFER OF TESTIMONY:

The testimony of the witness is being offered for the following purposes:

1. To prove that she is legally married to Raymond Edward Smith.


2. That she and her husband Raymond Edward Smith have only two (2)
legitimate children.
3. That Ms. Wilma Sarayan is her first cousin who offered her newly male
born child to be adopted by them.
4. That they have took custody of the child and later named as Charles.
5. Her husband procured Charles’ Birth Certificate in Manila and made it
appear therein that Charles is their natural and biological child.
6. She will identify certain documents and pieces of evidence and other related
facts.

I am Jinky Talon Smith, of legal age, married, resident of Block 18 Lot 61,
Brisas del Mar St., Alta Vista de Subic, Subic, Province of Zambales. I am being
interrogated by Atty. Eugene D. Kho, City Prosecutor in Quezon City at his office
which is located at Municipal Trial Court-National Capital Judicial Region, Branch
XLII (42) – Quezon City.

I am answering City Prosecutor Kho’s questions truthfully and based on my


personal knowledge knowing fully well that I do so under oath and that I may face
criminal liability for any false testimony.

Q1: Are you the same Jinky Talon Smith, the witness in this Criminal Case M-
QZN-16-08661-R before the Metropolitan Trial Court of Quezon City for
Falsification of Public Documents against Raymond Edward Smith?

1
A1: I am the same.

Q2: How are you related to Raymond Edward Smith?


A2: He is my legal husband.

Q3: How many children do you have?


A3: We have two (2) children.

Q4: What are their names?


A4: Genevieve Talon Smith and Emerson Talon Smith.

Q5: Do you know a certain Wilma Sarayan?


A5: Yes Sir.

Q6: How are you related to her?


A6: She is my first degree cousin.

Q7: Do you know Charles Edward Talon Smith?


A7: He is our adopted child.

Q8: How is Wilma Sarayan related to Charles Edward Talon Smith?


A8: She is the biological mother of Charles.

Q9: Do you and your husband went through the legal process of adoption?
A9: No sir. That is the reason why I filed a complaint against my husband. He
procured a falsified copy of Birth Certificate of Charles and he made it appear
therein that Charles is our natural child.

Q10: Do you have any proof that your husband Raymond Talon Smith engaged in
the procurement of such falsified document?
A10: Yes sir. He produced a copy of falsified Birth Certificate of Charles and
showed it to me. (Exhibit “A”)

Q11: How did your husband Raymond Talon Smith, procure this falsified
document?
A11: According to him, he engaged the services of someone whom he did not
identify to cause the registration of birth of Charles in Manila sometime in
November 2007.

Q12: What did you do at that time?


A12: I looked at the entries in the Birth Certificate and it was actually registered in
Quezon City and his signature over his name appeared therein as informant.

Q13: How did you react upon seeing the entries?


A13: I got angry at him because he made to appear that I am the natural mother and
he is the natural father of Charles when in truth and in fact we are not because
the child’s features alone would show that he was not his natural father.

Q14: Did you tell or talk to him regarding this matter?


A14: I told him the possibility that we would both be prosecuted criminally for the
falsity he has committed and he answered that we should not be afraid since
the people who allegedly prepared the document were highly connected to the

2
Civil Registry of Quezon City and were paid for the preparation and issuance
of the said document.

Q16: Do you have anything to add?


A16: I also want to add that he bluntly told me to forget the idea of filing a petition
for adoption in court since he did not want to spend money going to the court
for the purpose of adopting Charles. Thus, I went to this court and made the
necessary complaint-affidavit against my husband Raymond Edward Smith.

Q17: What did you do with the Complaint-Affidavit?


A17: I submitted it to the Quezon City Fiscal’s Office.

Q18: Now, do you affirm and confirm the contents of this Judicial Affidavit?
A18: Yes sir.

IN WITNESS WHEREOF, I hereby affix my signature this 30th day of June


2014, in the Quezon City.

JINKY TALON SMITH


Affiant

ATTESTATION

I hereby attest that on this 30th day of June 2014, I have personally examined
the witness JINKY TALON SMITH; and that I have faithfully recorded or caused
to be recorded the questions asked and the corresponding answers thereto made by
her. I further attest that I nor any other person herein present, or assisting me, never
coached JINKY TALON SMITH regarding her answers.

Quezon City for the City of Manila. June 30, 2014.

EUGENE P. KHO
Lawyer- affiant
Counsel for Plaintiff
Quezon City
Contact No. 09127965444
ROLL No. 04380228
P.T.R. NO. A-08100718-1/3-8-2014 Q.C.

SUBSCRIBED AND SWORN to before me this 30th day of June 2014 in


Quezon City. Affiant exhibited to me their identification cards bearing their
photograph and signature, as follows:

Name: Issued by/ID No.:


JINKY TALON SMITH SSS ID – No 13-1922
EUGENE P. KHO IBP No. – 1108018

3
known to me to be the same persons who executed the foregoing document.

WITNESS MY HAND AND SEAL on the date and at the place first above-
written.

Atty. Quinnee S. Vallejos


Notary Public
Commission Serial No. 135791
Notary Public for Olongapo City
Until December 31, 2015
Office: Banuanbayo, Olongapo City
Roll No. 123456
IBP Lifetime Roll No. 12345-56;
PTR No. 123457-04/13/14 ; OC
MCLE Compliance Cert. No. 689101;
01/09/14

Doc. No. _____;


Page No. _____;
Book No._____;
SERIES of 2014.

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