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Republic of the Philippines


National Capital Judicial Region

- versus -

Civil Case No.__________

For: Declaration of Nullity
of Marriage


PETITIONER, by counsel, unto this Honorable Court, most respectfully
states THAT:
1. Petitioner is of legal age, married, Filipino citizen, and with postal
address at 124 Leon Guinto St., Malate, Manila, where she may be served with
summons and other court processes of this Honorable Court;

2. Respondent is of legal age, married, Filipino citizen, and with residence

and postal address at No. 49 Estrada St., Malate, Manila;

3. Petitioner and respondent had been joined in marital union on January

5, 2002 at Our Lady of the Miraculous Medal in Praaque City. Copy of the
marriage contract is hereto attached as annex A;

4. The parties lived together as husband and wife until petitioner slowly
discovered of respondents pervasive utter lack of love, respect and support. The
following events and circumstances led to this case;

4.1 The petitioner and respondent met sometime in September 1999, at

Griffith Laboratories in Taguig City, where they were both employed. They went
along well and respondent courted the petitioner in January 2000, their
relationship blossomed into romance and they become sweethearts;

4.2 They boyfriend and girlfriend relationship at first was good but
problems in their relationship surfaced due mainly to respondents extreme
arrogance and extreme self importance, extreme lack of sensitivities to petitioner
and their marriage, extreme arrogance and extreme attachment to his family. His
failure to make decisions for himself and his gross dependence to his family
when it comes to decision making;

4.3 When they were about to get married, petitioner broke up with
respondent and she cancelled their wedding because of the extreme inability of
the respondent to decide and make decisions for himself and their relationship.
But thru the repondents promise to improve, petitioner married the respondent;

4.4 Petitioner, during the course of their marriage, wanted to assume the
role of a submissive wife but respondent did not make any effort to make
decisions for them but nevertheless extremely defiant to petitioners decision.
Respondent entirely depended on his family for the decisions he will make.
Respondent was very sensitive to criticism, irresponsible, impatient, hot headed
and wanted that all his demands will be complied with immediately, aside from
being severely unfaithfully;

4.5 One time during an office outing in Laguna, she observed respondent
busy texting messages to someone and before they went home respondent

asked petitioner to talk to his officemate and her husband, it turned out it was a
confrontation because he has an affair with his officemate and that was
discovered by her husband. Petitioner leaned during the confrontation that
respondent and the woman has an extra-marital affairs. To save his face during
the confrontation, respondent directed the petitioner to defend him by denying for
him the said affair in front of the partner of his other woman;

4.6 Petitioner was so hurt after the confrontation. She wanted to separate
with respondent but respondents family intervened by deciding for the
respondent to resign from work to separate respondent from his woman.
Petitioner gave the marriage another chance but this time she refrained from
having sex with him;

4.7 Respondent remained jobless, maintained a mistress and remained

very dependent on his family. He blamed petitioner for everything for everything
and their relationship was full of rage and disdain on the part of the respondent;

4.8 Petitioner tried to rebel because of their situation because the

respondent was always bringing out the worse in her. Their relationship had
become worse each day. They separated and when petitioner wanted to
reconcile with respondent, he was nowhere to be found. Petitioner learned that
he was already living with another woman;

5. In the course of their marriage respondent failed to discharge the

essential marital obligations. He is suffering from psychological incapacity
clinically identified as NARCISSISTIC PERSONALITY DISORDER which grave,
deeply-seated and incurable which deferred him from appropriately discharging
his marital obligations. This is characterized by jurisdictional antecedence, as the
same existed even prior to his marriage with the petitioner. A copy of the
psychological Report concerning respondents psychological Report concerning
respondents psychological incapacity is hereto attached as Annex B;

6. The parties have no properties of probable value and character;

7. The circumstance attendant to the herein party spouses falls squarely

within the provisions of Art. 36 of the Family Code.


WHEREFORE, it is respectfully prayed for unto this Honorable Court that

judgment be rendered declaring the marriage between herein petitioner and
respondent NULL AND VOID under Art. 36 of the Family Code.

Other reliefs just and equitable under the premises are likewise prayed for.

City of Manila August 11, 2010.


Counsel for the petitioner
Ground Floor, Unit II, Commercial Bldg. II
Provincial Capitol Compound, Manila
IBP No. 7777777/ 1.06.10-Bulacan
PTR No. 143278/ 1.11.10-Hagonoy
Roll No. 40951
MCLE COMPLIANCE No. III-0006465/ 12.02.09


I, MAE ANG, of legal age, after having been duly sworn in accordance with law,
depose and state that:
1. I am a plaintiff in the above-stated case;
2. I caused the preparation of the foregoing complaint;
3. I have read the contents thereof and the facts stated therein are true and
correct of my personal knowledge and/or on the basis of copies of documents
and records in my possession;
4. I have not commenced any other action or proceeding involving the same
issues in the Supreme Court, the Court of Appeals, or any other tribunal or
5. To the best of my knowledge and belief, no such action or proceeding is
pending in the Supreme Court, the Court of Appeals, or any other tribunal or
6. If I should thereafter learn that a similar action or proceeding has been filed or
is pending before the Supreme Court, the Court of Appeals, or any other tribunal
or agency, I undertake to report that fact within five (5) days therefrom to this
Honorable Court.


SUBSCRIBED AND SWORN to before me this 11 AUG 2010 in

MANILA affiant exhibiting to me his Community Tax Certificate No. 1111111111
issued on 2 MAY 2008 in the City of Manila.

Doc. No. ;
Page No. ;
Book No. ;
Series of 200_.