Republic of the Philippines

REGIONAL TRIAL COURT

Tenth Judicial Region
Branch No. _____
Malaybalay City

PAULINA G. BRAA, CIVIL CASE NO. __________

Petitioner,
FOR: Violation of R.A. 9262
vs

1.
RODOLFO V. BRAA,

Respondent.

_________________________________________

COMES NOW the petitioner, PAULINA G. BRAA, by this

undersigned counsel and to this Honorable Court, respectfully
submits this ________________________, and avers the following:

1. PURE LIES- It was respondent who immediately grumbles and

uttered degrading and humiliating names towards me such as
Bigaon, Baboy, and Buwaya. I calmly approached him and
instead hit me with a plastic mono block chair. I sustained injuries
due to respondents physical abuse by which I was able to
immediately get photographs herein attached as Annex A,
report the same to the Police Station in which a Police Blotter
Report was issued (previously attached to the Petition for
Protection Order as Annex B, C and C-1). On the same
date, I was examined by a government physician and issued a
Medical Certificate (previously attached to the Petition for
Protection Order as Annex E).

2. Respondent claimed that my Medical Certificate belied my

allegations of physical violence committed by him against me.
Such is an erroneous conclusion of law.

3. Respondent also claimed that he is sickly and his sickness could

not warrant of doing my accusation. It is true that respondent is
already 80 years of age, since it is a fact that my husband is only
____ years older than me. However, we both are still of food health
and it is a lie that my husband is dependent on oxygen. The only
time that he was on oxygen was when he was in hospital due to
his asthma. The Medical Certificate submitted by respondent both
dated July 13, 2015 for his hospitalization last March 2015 and
May 2015 merely showed that he had lung problems such as
Chronic Obstructive Pulmonary Disease (COPD) in exacerbation
(pulmonary tuberculosis, commonly acquired all of the _____ are
 characterized by pneumonia , shortness and noisy breath and
coughing) and degenerative disc disease. None of the illness of
respondent would show that he no longer has the strength to
inflict physical and psychological violence upon me.

4. It is pure falsity when respondent alleged that he was the one who
attended to the growth and care of my children because I was
used to leaving our family home and went to ____ when I am
bored. The truth is that respondent and I have lived separately for
long time due to the infidelity of respondent involving a several
women which started with one of my workers in the carinderia and
the last mistress he had whom he lived with at Gusa, Cagayan de
Oro City who recently died. In fact, the mistress of respondent, in
her lifetime, also filed a case for violation against women against
respondent which shows the latters propensity and history of
inflicting harm to his partner.

5. It is an upfront against my person as a mother when respondent

attempts a picture of me as an irresponsible mother. My son and
his family lived at Lapasan, Cagayan de Oro City when he died last
March 2015, I readily allowed the family of my son to have his
internment and burial in Kisolon, Sumilao, Bukidnon and took care
of the expenses thereof.

6. All these claims of respondent that I utter harsh and bad

languages against anybody in the house and that I was a nagger,
all of these are lies, The truth is that since respondent returned to
our house last week, respondent continuously degrades my dignity
as a person and as a woman when she alleges in his
Opposition/Counter-Affidavit that I am merely fabricating my
statements to attract attention from my family since I have no
good relation to my children. My daughter, Ma. Arcelli B. Tusay, her
husband and children would have not lived with me in our
residence at Kisolon, Sumilao, Bukidnon for several years if I was
estranged from my family.

7. The allegations of possible senility or dementia which requires

psychological attendance do not refer to me but actually applies to
respondent himself. I am completely sane and of good condition,
physically, mentally and emotionally. For a long time, I have
peacefully lived my life after respondent left our family home to
live with his mistress and it is only upon the return of respondent
in our house more than a year ago that my peaceful existence and
kife in our house was rudely interrupted with respondents
presence coupled with his violent behavior.

8. This Petition for Protection Order would give me peace of mind if

respondent would be mandated by this Honorable Court not to
continue with his violent behavior, especially that I am very fearful
of my life and security su=ince respondent has in his possession a
short firearm.

Done this _____ of July 2015 at Malaybalay City, Philippines.

By:

ATTY. RIA FAITH N. BISAHAN

Malaybalay City, Bukidnon
Attorneys Roll No. 60222 (Admitted to the Bar: March 22, 2012)
PTR No. 0006296 issued at PTO (Bukidnon) on January 5, 2015
IBP No. 915771 issued by IBP (Bukidnon) on January 5, 2015
MCLE COMPLIANCE NO. IV-0007660

Contact Details:
BISAHAN LAW OFFICE
2nd Floor, Landbank/Belsar Building, Sayre Highway, Barangay 4,
Malaybalay City
Telephone No. (088) 813-5800
Email Address: rapet_bisahan@yahoo.com

Copy furnished:
RODOLFO BRAA
Kisolon, Sumilao
Bukidnon, Philippines
Republic of the Philippines )
Province of Bukidnon )
City of Malaybalay ) S.S

VERIFICATION

I PAULINA G. BRAA, of legal age, Filipino, married and a resident of

Kisolon, Sumilao, Bukidnon, after having been duly sworn to in accordance
with law, hereby depose and state:

1. That, I am the Petitioner in the civil case entitled PAULINA G.

BRAA vs RODOLFO V. BRAA, filed before the RTC of
Bukidnon, Malaybalay City, for Violation of RA 9262;

2. That, I have caused the preparation and consequent filing of the

foregoing Petition for Issuance of Permanent Protection
Order with Urgent Ex-parte Prayer of Issuance of Temporary
Protection Order and that I have read the contents thereof;

3. That, the factual allegations therein are true to my knowledge and

on the basis of genuine documents;

IN WITNESS WHEREOF, I have hereunto set my hand this ______ day

of July 2015 in the City of Malaybalay, Bukidnon, Philippines.

PAULINA G. BRAA
Petitioner

SUBSCRIBED AND SWORN to before me this ___ day of July 2015, in

the City of Malaybalay, Bukidnon, Philippines, affiant exhibited to me her
___________________________________, as sufficient proof of her identity. I
hereby further certify that I have personally examined the affiant and I am
satisfied that she understood the contents of the foregoing statement and
voluntarily executed the same
 ATTY. RIA FAITH N. BISAHAN

Malaybalay City, Bukidnon

Attorneys Roll No. 60222 (Admitted to the Bar: March 22, 2012)

PTR No. 0006296 issued at PTO (Bukidnon) on January 5, 2015

IBP No. 915771 issued by IBP (Bukidnon) on January 5, 2015

MCLE COMPLIANCE NO. IV-0007660

Contact Details: