Republic of the Philippines

REGIONAL TRIAL COURT

SECOND JUDICIAL REGION
Branch 15
Alfonso Lista, Ifugao

ADONIS SATURNO, CIVIL CASE NO.

________________
Plaintiff,
For:
-Versus-
DECLARATION OF NULLITY
DEBBIE REMBULAT-SATURNO, OF MARRIAGE
BASED ON Defendant.
PSYCHOLOGICAL INCAPACITY

COMPLAINT

WITH UTMOST RESPECT TO THIS HONORABLE COURT.

P
this
LAINTIFF, assisted by counsel undersigned, most respectfully files
this Complaint and for this purpose states that –

1. He is a Filipino citizen, of legal age, married to the

defendant, and a resident of Santiago City, Isabela; whereas
the defendant is likewise of legal age, Filipino, married to the
plaintiff and a resident of (Afonso Lista, Ifugao);

2. The plaintiff had the first glimpse on the defendant

sometime in middle of 1999 while he was in Manila for
vacation and where the defendant was then working.
Attracted, the plaintiff immediately started courting the
defendant shortly after being introduced to each other.
Following a brief and superficial courtship, the parties soon
became lovers;

3. From the onset of their budding relationship, the plaintiff and

the defendant had already engaged in unprotected pre-
marital sex that the latter eventually became pregnant as a
consequence thereof. If only to save face from familial
derision and public ridicule, the parties decided in haste to
get married while the defendant was still in her fifth month
of pregnancy;

COMPLAINT Page | 1
 4. And so the plaintiff and the defendant were married in a
simple rite before the Office of the Municipal Mayor of Kalibo,
Aklan despite of the fact that they barely know each other’s
character and personality. For them, their marriage also
serves as a major step to adhere to their responsibilities as
expecting parents; 

A copy of the parties’ Certificate of Marriage is attached, and made an

integral part of this Complaint, as ANNEX “A”;

5. After their marriage, herein parties then lived together as

husband and wife. They were compelled to stay at the place
of the plaintiff’s parents in Santiago City, Isabela as the
parties have no house of their own. On September ____ 2000,
the defendant gave birth to their first and only child whom
they named ALESSANDRA R. SATURNO;

A copy of the child’s Certificate of Live Birth is marked as ANNEX “B”

and likewise attached to form part hereof;

6. The arrival of their child is of course a joyous event but it

certainly entailed more expenses also. So in order to be able
to meet the growing needs of his family, the plaintiff, while
initially adamant as it would mean that he will be physically
separated from his wife and infant child, accepted a job
overseas in the long run. Both the defendant and their child
were thus left in Santiago City, Isabela together with the
plaintiff's mother; 

7. Plaintiff would regularly send money to the defendant when

he was already working in the humid province of Jeddah,
Kingdom of Saudi Arabia. His newfound role as a father
surely inspired him to work his heart out.   But sad news
from the Philippines soon dishearten plaintiff. Reports about
the defendant frequently leaving the house, even in the wee
hours of the day and without the knowledge of plaintiff or his
mother, started to reach the plaintiff. Moreover, the
defendant is likewise slackening in the manner she looks
after their sole child who is often left merely in the care of
plaintiff’s mother. Friction slowly begins to abrade the
relationship of the defendant and her mother-in-law while
the child’s feeling commences to be alienated from the
former;

8. But while the defendant is so busy gallivanting and enjoying

parties every after parties with friends, the plaintiff mustered
all the courage that he could summon to carry on breaking
his back at work if only to provide for their daughter.
Homesickness is yet another enemy which he has to battle
on a daily basis. Despite all these, the welfare of Alessandra

COMPLAINT Page | 2
 is what the plaintiff had been considering. And that is all that
only matters to him;

9. Defendant did not slow down with her escapades and worse
she later develops an extra-marital affair with another man.
After several months the defendant suddenly left Santiago
City, Isabela and took the child with her sans approval of
plaintiff. The plaintiff will learn thereafter that the defendant
eloped and lived with yet another man in Alfonso Lista,
Ifugao. Soon she became impregnated before finally giving
birth to another child named VICTORIA VILLARDE REMBULAT.
The child’s fact of birth and other material details are
evidenced by a Certificate of Live Birth, a copy of which is
hereto attached as ANNEX “C”;

10. Plaintiff’s world seemingly turned upside down. Like what are
seen in tear-jerking dramatic movies and television soap
operas, his heart seems being pierced every time the sorry
state of his marriage crossed his thoughts. Only that in his
case, the pain is very real! True, the fate of his marriage is
no less different from the numerous other accounts of male
OFWs where man works abroad, leaves woman behind only
to go with another man later. These stories, although
admittedly clichéd, were aptly epitomized in that classic OPM
hit song popularized in the mid 1980’s by Roel Cortez the
title of which best describes the plaintiff’s feeling –
“Napakasakit Kuya Eddie”. So to alleviate his suffering,
plaintiff opted to stay in the afore-said oil rich country for
quite some times. He preferred to endure the hardships of
work rather than to go home and relish firsthand his
relationship with the defendant that had become so
wretched to stomach;

11. In all those years that plaintiff had been working overseas
since the defendant walked-out from his life, the former
never had any communication much less personal contact
with the latter. Bits of information about defendant’s life
were only relayed through relatives and friends. The parties
have been separated for barely one and half decade or
fourteen (14) long years to be exact;

12. Clearly, the defendant is psychologically incapacitated to

perform, as she had in fact failed to perform, the essential
obligations of marriage as mandated by law like to live
together, observe mutual love, respect and fidelity, and
render mutual help and support;

13. Yet, in one way or another, the demise of the parties’

marriage could also be attributed to herein plaintiff. He too
cannot be held blameless. He could only surmise that had

COMPLAINT Page | 3
 just remained in the country, perhaps he could have had
prevented or decelerated the immediate deterioration of
their marital relations at the very least. But then again, his
primordial concern was to improve the economic condition of
his family. May not be too much but not less. Their
unresolved issues coupled by the vast time and distance
between the parties therefore led them apart from each
other until their union finally reached a totally deteriorated
state;

14. Prior to the marriage, and during their marital life, the
parties exhibited permanent, incurable, and grave
personality disorders which prevented them from fully
appreciating and complying with the marital obligations
required of them under the Family Code. Their respective
personality disorders had existed prior to the celebration of
the marriage albeit the manifestations showed later during
the marital relationship. As a consequence thereof, the
parties were never able to undertake any of the marital
obligations enumerated under the Family Code of the
Philippines;

15. The parties did not acquire any properties in the course of
their marriage neither do they own any conjugal properties
that could be the subject of partition or division;

16. Devastated once, the plaintiff had finally come to realize that
life must still go on. And in his quest to have a fresh start, he
now seeks the aid of the Honorable Court so that after due
notice and hearing, the marriage he contracted with the
defendant be declared null and void pursuant to Article 36 of
the Family Code of the Philippines;

PRAYER

WHEREFORE, premises considered, it is most respectfully

prayed of this Honorable Court that, after due notice and hearing,
judgment be rendered:

a. Declaring the marriage of the Plaintiff and the Defendant

NULL AND VOID in accordance with Article 36 of the Family
Code setting them free from the effects of the marital bond;
and

b. Furnishing all pertinent government offices a copy of the

Decision of the Honorable Court

COMPLAINT Page | 4
 Plaintiff finally prays for such other remedies which may be
just and equitable under the premises.

RESPECTFULLY SUBMITTED. At Lagawe for Alfonso Lista,

Ifugao this 8th day of _________________ in the Year of the Lord, Two
Thousand and Fifteen.

B u y a g a w a n(on leave) & P a n h o n

Law Office
No. 27 JP Rizal Avenue, Poblacion East
Lagawe, Ifugao 3600

-By-

ATTY. RAYMOND G. PANHON

-Counsel for the Plaintiff-
PTR No. 2528052; January 9, 2015; Lagawe, Ifugao
IBP No. 955585; January 7, 2015; Ifugao Chapter
Roll of Attorneys No. 55498; May 2, 2008, Manila
MCLE Comp. No. IV 0008053/September 24, 2012
Mobile No. 0927 7997 522
Email: raymondpanhon@yahoo.com

Copy Furnished:

OFFICE OF THE PROVINCIAL PROSECUTOR

Lagawe, Ifugao

OFFICE OF THE SOLICITOR GENERAL Registry Receipt No.

_____________
134 Amorsolo Street, Legaspi Village Date. ___________
1229 Makati City, Metro Manila

EXPLANATION
[Pursuant to Sec. 11, Rule 13 of the Rules of Civil Procedure]

As personal service is impracticable due to far distance between Ifugao and

Makati City, a copy the foregoing Complaint was furnished the Office of the Solicitor
General through registered mail as shown the attached registry receipt.

COMPLAINT Page | 5
 RAYMOND G. PANHON

COMPLAINT Page | 6