Professional Documents
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JDRC No.8364-51
For: Declaration of Nullity of Marriage
GRETCHEN B. GENOVEZA-BERNARDO,
Respondent,
x----------------------x
PRE-TRIAL BRIEF
PETITIONER by the undersigned counsel and unto this Honorable Court
most respectfully states:
STATEMENT OF THE FACTS AND OF THE CASE
This is an action for Declaration of Nullity of Marriage under Articles 36 & 68
of the New Family Code.
Petitioner alleges in his Petition, viz: a) that petitioner and respondent are
husband and wife; b) that both respondent and petitioners are clinically found to be
psychologically incapacitated to comply with the essential requisites of marriage
identified as Narcissistic Personality Disorder with Anti-Social Traits while
respondent is suffering with Histrionic Personality Disorder; c) that the root cause of
such illness is traced from their respective childhood; d) such illness is diagnosed to
be grave and incurable; e) that such illness existed prior to the marriage and
became apparent at the time of the marriage.
Petitioner likewise alleges that a child was born in wedlock and their de-facto
separation which culminated from petitioners frustration of respondents mercurial
change of disposition, abusive and manipulative conduct, immaturity, excessive
spending and adulterous conduct. That respondent failed to give love, emotional
support and fidelity to the marriage.
PROPOSED STIPULATION OF FACTS
1.
2.
3.
4.
5.
Report-----Exhibit
ABSTRACT OF TESTIMONIES
"C
Petitioner will be testifying on the allegations in the Petition and will present
documentary evidence.
Page 02.
The Clinical Psychologist who will testify on the psychological
done on both petitioner and respondent.
evaluation