REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

NATIONAL CAPITAL REGION
QUEZON CITY, BRANCH CIV
ELIZABETH SCHUYLER HAMILTON,
Civil Case No. 15-56789-CIV
Plaintiffs,

- versus
SEPARATION

For: PETITION FOR LEGAL

ALEXANDER HAMILTON
Defendants.
x---------------------------------------------x
JUDICIAL AFFIDAVIT
OF
HERCULES MULLIGAN

I.

PRELIMINARY INFORMATION.

A. NAME AND OTHER PERSONAL CIRCUMSTANCES

OF THE WITNESS.

Name

Age

HERCULES MULLIGAN
FIFTY-ONE (51) YEARS OLD

Address
:
Block 3 Lot 22 Atis Street, Fairview,
Quezon City, Metro Manila
Occupation
Language

Family Driver
:

English and Tagalog.

B. LAWYER WHO CONDUCTED OR SUPERVISED THE

EXAMINATION OF THE WITNESS.

Page 1 of 9

Name

YMIL RAJIV MATBA

Address
:
Aaron Burr Law Officers,
23rd floor, UP Town Center, Diliman, Quezon City

Place of Examination:
Aaron Burr Law Officers, 23rd
floor, UP Town Center, Diliman, Quezon City

II.

OFFER.

The testimony of the witness NENENG PISTASYO is being

offered to prove the:
1.

Existence of an amorous affair of Defendant,

Alexander Hamilton, during the existence of the valid
marriage between the Plaintiff and the Respondent

2.

Dates when Alexander met with Maria Reynolds

III.

JUDICIAL AFFIDAVIT PROPER.

I, NENEG PISTASYO, of legal age and sound mind, married,

Filipino, declare that I am fully conscious of the
consequences of the oath administered to me, and that I
might face criminal liability for false testimony or perjury, do
so declare:

1. Q Please state your name, age, residence, and

occupation of the witness.

A
I, HERCULES MULLIGAN, Filipino, fifty-one (51)
years of age, married, and a resident of Block 3 Lot 22 Atis
Street, Fairview, Quezon City, Metro Manila, Family
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2. Q- Why are you here now?

A To give a sworn statement by way of a judicial affidavit,

the same to constitute as my direct testimony, in the abovecaptioned civil case.

3. QFor the record, please state the name and

address of the Lawyer who is now conducting or
supervising your examination and the place where
the examination is being held now?

A The legal counsel for the plaintiffs, Atty. Ymil Rajiv Matba
(Aaron Burr Law Offices) 23rd Floor, UP Town Center,
Diliman, Quezon City
4. Q In what language do you want your examination to
be conducted?

This judicial affidavit is prepared in English.

But I prefer that my cross examination be conducted

in Tagalog- English for my convenience and for clarity.

5. Q Do you undertake to answer the questions to be

asked of you, fully conscious that you will do so under
oath, and that you may face criminal liability for false
testimony or perjury?

A - Yes.

6.
Q Let us now proceed to the Complaint. Do you
know the parties in this case?
A Yes, they are my employers

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7.

A-

8.

9.

When did you begin your employment?

20 August 1999

Q-

What is it that you do for the Hamiltons?

Im their family driver.

Q - What did you do as their family driver?

A - That on weekdays, since the day of my employment, I

drive the whole family with their maid, Abigail Thomas; first,
to their son William Hamilton's school in Philippine Science
High School and then to Alexander Hamilton's office in the
Department of Finance Building, Roxas Boulevard, corner
Pablo Ocampo Street, Manila.
That Elizabeth Schuyler-Hamilton and the spouses' younger
child, John Hamilton, goes with with them on weekdays.
That on Saturdays, I always take the spouses to a dinner
place or wherever they decide to go.
That on Sundays, I take the whole family and the maid,
Abigail Thomas to church.
10.
QDid you notice anything else in the course of
your employment with the Hamiltons?

A Yes for a brief period while the rest of the family was on
vacation Mr. Hamilton was accompanied by another woman.

11. Q Would you be able to identify her if you saw a

picture?

A
Yes. (holds up a picture) Yes. That is the woman he
was with.
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12. Q Do you recall when you saw her accompanying

Mr. Hamilton?

A31 October 2011 and probably a few days after that

day as well.

13. Q - Where did you see them together?

AIn the doorway of the Hamilton Residence, doorway of

the womans house, in the car when I bring the woman
home.

14. Q -

You bring the woman you identified home?

A
Yes. It was early morning around 3am. I
recall it because it was unusual to be asked to bring
someone home on that hour.

She was in the car with Mr. Hamilton. They were very
affectionate.

15. Q Who asked you to bring her home?

A-

Mr. Alexander Hamilton

16. Q Did you tell Mrs. Hamilton about what you saw
while she was away?

No. I was asked by Mr. Hamilton not to say a word.

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17. Q -

Why are you testifying now?

A - Because Mrs. Hamilton plead to me to tell her what I

know of the events while she and her children were away on
vacation.
Nothing Follows.

Quezon City, 08 November, 2016.

HERCULES MULLIGAN
Affiant/Witness

SUBSCRIBED and sworn to before me in Quezon

City on 08 November 2016, affiant showing his/her
competent proof of identity, to wit: Comelec VIN 123.

Notary Public

Doc. No. 111

Page No. 111
Book No. 111
Series of 2016.

Page 6 of 9

IV.
SWORN ATTESTATION OF THE LAWYER
WHO CONDUCTED OR SUPERVISED THE
EXAMINATION OF THE WITNESS.

The undersigned ATTY. YMIL RAJIV MATBA., of legal age,

married, and with law office address are Aaron Burr Law
Offices, 08 November 2016 at 23rd Floor, UP Town Center,
Diliman, Quezon City, under oath, deposes and states:

1.
He is the Legal Counsel for the plaintiffs in the aboveentitled case;

2.
He faithfully recorded or caused to be recorded
the questions he asked and the corresponding answers
that the above-named witness gave;

3.
Neither he nor any other person then present or
assisting him coached the witness regarding the latter's
answers; and

4.
He conducted the examination of the witness at his
law office located at Aaron Burr Law Offices at 23rd Floor, UP
Town Center, Diliman, Quezon City

Quezon City, 08 November, 2016.

Atty. YMIL RAJIV

MATBA
Affiant
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SUBSCRIBED and sworn to before me in Quezon

City on 08 November 2016, affiant showing his/her
competent proof of identity, to wit: SSS Member ID No.
1234.

Atty. Ymil Rjiv D Matba,

Aaron Burr Law Offices,
23rd Floor, UP Town Center,
Diliman, Quezon City
Doc. No. 112
Page No. 112
Book No. 112
Series of 2016.

Copy Furnished:
Atty. Julia Herrera-Lim
Hamilton and Associates
5th floor, Bahay ng Alumni,
University of the Philippines,
Diliman, Quezon City
EXPLANATION

A copy of this Judicial Affidavit is served on the

Court, the Counsel for the Defendant Alexander Hamilton via
LBC Express Corp./registered mail due to the great distances
of their respective addresses, due to the urgency of filing the

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same, and due to the lack of field personnel of the

undersigned counsel at this time.

YMIL RAJIV MATBA

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