Republic of the Philippines ]

C I T Y O F D A V A O ] ss.
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JUDICIAL AFFIDAVIT of
DR. JEZREEL NOVENO

I, Dr. Jezreel Noveno, Filipino, 57 years old, married and
residing in Marfori Heights, Davao City, under oath, hereby state that:

1. I was examined by ATTY. Marnelli Laurel, who is holding
office at the 7
th
Floor Abreeza Corporate Center, Bajada,
Davao city.

2. I answered the questions the examining lawyer asked and I
do so under oath, knowing fully that I may face criminal
liability for false testimony or perjury.

The questions she asked me and my corresponding answers
are as follows:


1. Q: What is your name?
Expert Witness: I am Dr. Jezreel Noveno

2. Q: What is your line of work?
Expert Witness: I am a licensed physician with
specialization in General Surgery, Hepatobiliary and
Pancreatic Surgery, Laparoscopic and Endoscopic
Surgery

3. Q: How many years have you been working as a
Surgeon?
Expert Witness: I have been working as a surgeon for
28 years.

4. Q: What accomplishments do you have in relation
to your medical profession?
Expert Witness: I completed my medical education
including internship at Cebu Institute of Medicine,
Cebu City. After I passed the licensure examination for
physicians, I worked as a Resident in General Surgery
at the Cebu Velez General Hospital (CVGH) for 5
years. I thereafter had my fellowship on general
surgery with training emphasis on Hepatobiliary and
Pancreatic Surgery, Laparoscopic and Endoscopic
Surgery at Mayo Clinic in Florida, USA for 2 years.
After I returned from my training at Mayo Clinic, I
became a Consultant responsible for Training and
Education of Residents and Fellows of the Division of
Hepatobiliary and Pancreatic Surgery, Laparoscopic
and Endoscopic Surgery, Department of Surgery, at
the Cebu Velez General Hospital for four years. From
1993 up to present I am a consultant at the Cebu
Velez General Hospital and Cebu Doctors Hospital.

5. Q: Aside from the abovementioned, what else are
your accomplishments as a surgeon.
Expert Witness: I also served as the Vice-President of
the Philippine College of Surgeons and Philippine
Society of General Surgeons, Inc. from year 2001-
2003 and from year 2006-2009 respectively.


6. Q: At present, what hospital/ hospitals are you
affiliated?
Expert Witness: I am affiliated with Cebu Velez
General Hospital (CVGH) and Cebu Doctors Hospital.

7. Q:Aside from being affiliated with those hospitals,
what else do you do in connection with your
profession?
Expert Witness: At present, I am also a Clinical
Professor at the Cebu Institute of Medicine, Cebu City.


8. Q: Mr. Expert Witness, when a patient suffers
severe abdominal pain, what is the standard
procedure followed by physicians?
Expert Witness: We take the medical history and
physical examination as part of our assessment. We
identify the location of pain, the quality or type of pain
and the intensity of the pain. Laboratory and diagnostic
examinations are also performed whenever necessary.


9. Q. What is the procedure before a patient can be
subjected to procedures like surgery?
Expert Witness: First, the surgeon will give an
explanation as to the type of operation, technique
used, and reasons why the procedure should be
performed. The surgeon will also explain the options if
the procedure is not done. The expected and possible
benefits as well as the possible complications of the
procedure are also explained to the patient and to his
family.


10. Q: After explaining the possible complications of
the suggested surgery, what should be the next
procedure?
Expert Witness: The physician should secure consent
from the relatives or the patient himself for the
administration of the procedure.


11. Q: What else should the physician do before
getting the consent of the patient?
Expert Witness: The Physician should also ask the
patient or the relatives whether they understood the
explanation.

12. Q: What are the patients responsibilities while
undergoing treatment under the supervision of a
physician?
Expert Witness: Patients must consider the
consequences of refusing treatment or not following
medical advice . They must also accept responsibility
for their own actions. Patients must also tell the
medical staffs if they are uncertain or dont understand
any aspect of their treatment. They are also duty bound
to tell the medical staffs about any change in their
health that could affect the treatment they are having.
They also have the responsibility to take any medicines
as instructed and seek medical advice before stopping
or changing treatment.


13. Q: When is there a need to conduct ERCP?
Expert Witness: ERCP is performed whenever
there is a need to diagnose and treat certain
problems of the biliary or pancreatic ductal systems.

14. Q: How is it performed?
Expert Witness: The procedure combines the use of
endoscopy and fluoroscopy. The physician can see
the inside of the stomach and duodenum and inject
radiographic contrast into the ducts in the biliary
tree and pancreas so they can be seen on X-rays.

15. What is the major risk of ERCP if any?
Expert Witness: The major risk of an ERCP is the
development of pancreatitis which can occur in up
to 5% of all procedures. This may be self limited
and mild but may require hospitalization and rarely
may be life-threatening. Gut perforation is also a
risk of any endoscopic procedure and is an
additional risk if a sphincterotomy is performed.
There is also a risk associated with the contrast dye
in patients who are allergic to compounds
containing iodine.


16. Q: When is exploratory laparotomy performed?
Expert Witness: An exploratory laparotomy is a
laparotomy performed with the objective of
obtaining information that is not available via
clinical diagnostic methods. It is usually performed
in patients with acute or unexplained abdominal
pain, in patients who have sustained abdominal
trauma, and occasionally for staging in patients
with a malignancy.

17. Q: When can an exploratory laparotomy be
performed instead of a cholecystectomy or a
choledocholithotomy?
Expert Witness: It is possible that relevant
pathology may be missed as a result when only a
cholecystectomy or a choledocholithomy is
performed instead of an exploratory laparotomy.
This is especially true when the physician suspects
some other underlying cause for the patients signs
and symptoms. Apart from that, an abdominal
exploration may be needed to get an exact
diagnosis of the patients illness despite the fact that
some problems inside the organs in the abdomen
can be easily diagnosed with imaging tests such as
x-rays and CT scans.

18. Q: What is performed in an exploratory
laparotomy that is not performed in a
laparoscopic cholecystectomy or
choledolitotomy?
Expert Witness: In an exploratory laparotomy , the
abdominal organs in question will be examined for
evidence of infection, inflammation, perforation,
abnormal growths, or other conditions. Any fluid
surrounding the abdominal organs will be inspected;
the presence of blood, bile, or other fluids may
indicate specific diseases or injuries. In some cases,
an abnormal smell encountered upon entering the
abdominal cavity may be evidence of infection or a
perforated gastrointestinal organ.

On the other hand, Laparoscopic cholecystectomy
requires several small incisions in the abdomen,
through which surgical instruments and a video
camera are placed into the abdominal cavity. The
surgeon watches the monitor and performs the
operation by manipulating the surgical instruments
through the operating ports. Choledocholithotomy
is the incision of the common bile duct for the
extraction of an impacted gallstone.

19. Q: What are the other conditions that can be
predicted only during exploratory laparotomy and
not in a cholecystectomy or
choledocholithotomy ?
Expert Witness: A number of other conditions that
may be predicted during exploratory laparotomy are:

Cancer of the abdominal organs, such as
ovary, colon, pancreas, liver.

Peritonitis (inflammation of the peritoneum,
the lining of the abdominal cavity)

Appendicitis (inflammation of the appendix)

Pancreatitis (inflammation of the pancreas)

Abscesses (a localized area of infection)

Adhesions (bands of scar tissue that form
after trauma or You do not have access to
view this node)

Diverticulitis (inflammation of sac-like
structures in the walls of the intestines)

Intestinal perforation

Ectopic pregnancy (pregnancy occurring
outside of the uterus)

Internal bleeding.


20. When can a second exploratory laparotomy be
performed?
Expert witness: Once the underlying pathology has
been determined, an exploratory laparotomy may
continue as a therapeutic procedure; sometimes, it may
serve as a means of confirming a diagnosis .These
applications are distinct from laparotomy performed for
specific treatment, in which the surgeon plans and
executes a therapeutic procedure.

21. Q: How is exploratory laparotomy performed?
Expert Witness: The abdominal skin is incised with a
surgical knife in order to open the peritoneum. There is
thereafter an exploration of the abdominal cavity. The
steps of exploration depend on the initial findings and
are governed by the principles of systematic survey
and priority for life-saving maneuvers. Once the
procedure is completed, the abdominal wall is closed.

22. What happens after the procedure?
Expert Witness: The patient will remain in the
postoperative recovery room for several hours
where his or her recovery can be closely
monitored.

23. When can the patient be discharged?
Expert Witness: Discharge from the hospital may
occur in as little as one to two days after the
procedure, but may be later if additional procedures
were performed or complications were encountered.
The patient will be instructed to watch for symptoms
that may indicate infection, such as fever, redness
or swelling around the incision, drainage, and
worsening pain.

24. What are the complications of the procedure?
Expert Witness: An exploratory laparotomy is
associated with the same complications that are
associated with any laparotomy. The complications
may include the following:
Paralytic ileus
Wound infections
Abdominal wall dehiscence
Pulmonary atelectasis
Enterocutaneous fistula
Adhesive intestinal obstruction
Incisional hernia


IN WITNESS WHEREOF, I hereby affix my signature this 8th
day of

January 2014 in Davao City, Philippines.


DR. JEZREEL NOVENO
Affiant


SUBSCRIBED AND SWORN TO before me this 8th day of

January 2014 in Davao City, Philippines. The affiant-witness DR.
JEZREEL NOVENO exhibited to me his Community Tax Certificate
No. 3823512 issued on 17 February 2013 in Davao City as proof of
his identity and for purposes of proving that he voluntarily executed
the foregoing instrument and fully understood the contents thereof.

Witness my hand and seal.

ATTY. RESCI ANGELLI RIZADA
Notary Public Davao City
Until 31 December 2014
Notarial Commission No. 024537
Roll No. 87111
Doc. No. __ PTR No. 745823- 1/2/2014
Page No. __ TIN 08-312-112
Book No. __ IBP O.R. 832123- 01/2/2014
Series of 2014. Davao City




ATTESTATION

I, ATTY. MARNELLI O. LAUREL, of legal age, Filipino, single,
residing in Davao City, Philippines with office address at the 7
th
Floor
Abreeza Corporate Center, Bajada, Davao city.
Philippines under oath hereby state that:

1. I conducted and supervised the examination of JAMES
SANDEJAS as witness of the above-entitled case;
2. I faithfully caused to be recorded the questions I asked and the
corresponding answers the said witness gave; and,
3. Neither I nor any other person then present or assisting me
coached the witness regarding her answers.

IN WITNESS WHEREOF, I hereby affix my signature this 8
th

day of

January 2014 in Davao City, Philippines.

ATTY. MARNELLI O. LAUREL


SUBSCRIBED AND SWORN TO before me this 8th day of

January 2014 in Davao City, Philippines. She presented to me her
drivers license as competent evidence of her identity.

Witness my hand and seal.

ATTY. RESCI ANGELLI RIZADA
Notary Public Davao City
Until 31 December 2014
Notarial Commission No. 024537
Roll No. 87111
Doc. No. __ PTR No. 745823- 1/2/2014
Page No. __ TIN 08-312-112
Book No. __ IBP O.R. 832123- 01/2/2014
Series of 2014. Davao City