Republic of the Philippines

REGIONAL TRIAL COURT

11th Judicial Region
Branch 34

CHING CHONG
Plaintiff,

Civil Case No. 1232156

- versus - For: Separate Support and
Alimony Pendente Lite

JING CHONG
Defendant.
x---------------------------------------x

COMPLAINT

Plaintiff, by the undersigned counsel, and unto this Honorable court,

respectfully avers that:

1. The Plaintiff is of legal age, Filipino and a resident of Nha

Buhangin Davao City. The Defendant is Filipino, of legal age
residing at km6. Sasa Davao City.
2. The Plaintiff and the Defendant, are wife and husband,
respectively, having been married in Manila on February 14, 1996;
3. The Plaintiff was pursuing a law degree when the Defendant
proposed that they get married. The Plaintiff hesitated at first as
she wanted to finish her law degree but the Defendant said that
nothing will change after the marriage, that she can continue her
law degree and that he will support her financially. Plaintiff’s
parents did not approve of the marriage but they got married
anyway. Upon the Defendant’s request, Plaintiff eventually agreed
to drop out of law school to take care of their children;
4. During the marriage, three children were born namely: a. Andrew
Suarez Jr. (ANDREW JR.) born on January 5, 1997; b. Sophia
Suarez (SOPHIA) born on October 12, 2000; and c. Penelope
Suarez (PENELOPE) born on February 14, 2004;
5. During the marriage, the Defendant was able to establish his own
Computer technology firm named, Tech Solutions, Inc. which
blossomed into one of the most innovative computer software
providers in the country;
6. Up to December 2013, the marital relations between the Plaintiff
and the defendant were happy and harmonious, until January 2014
 when the Defendant started to care less of the Plaintiff and their
children. The Plaintiff heard stories from family, friends and co-
workers of the defendant about the latter’s “extremely close”
relationship with the company’s new business partner, Frida
Ramos (FRIDA). The Plaintiff dismissed the stories as mere
rumors;
7. On February 14, 2014, Valentine’s Day, their seventeenth wedding
anniversary and daughter, Penelope’s tenth birthday, the Plaintiff
and the Defendant planned a trip for the whole family – a two
week tour of Japan to see Disneyland, the Universal Studios,
Sanrio Puro Land and other tourist destinations. However, on
February 13, 2014, the Defendant cancelled the plans as he
allegedly had a business meeting to attend to. He did not go home
that day as the business meeting allegedly turned to a three-day
business trip to Hong Kong. The Plaintiff later on learned that the
cancellation of their plans was due to the Defendant’s illicit affair.
8. Similar instances happened later when the Defendant missed
family events such as Penelope’s ballet recital, Sophia’s graduation
and Andrew Jr.’s tech competition in South Korea;
9. The Defendant started going home less often reasoning that the
merger of companies is taking too much of his time.
10. On August 15, 2014, Frida called the Plaintiff saying that she
wants to “catch up” with her. The Plaintiff met up with Frida at a
coffee shop and Frida told her that she was having an affair with
the Defendant. Frida begged the Plaintiff to “release” the
Defendant as they are about to have a child together. The Plaintiff,
thinking it too incredulous to believe, stormed out of the coffee
shop;
11. That same day, the Plaintiff confronted the Defendant about Frida.
The Defendant confessed that he had been having an affair with
Frida since December 2013. The Plaintiff wanted to separate with
the Defendant right there and then, but the Defendant begged for
forgiveness. The Defendant told her that the probable reason why
Frida met with her and told her she was pregnant was because he
ended the relationship a week prior. She decided that, for the
children, she should stay with him.
12. Their relationship never returned to normal and on October 24,
2014, the Defendant informed the Plaintiff that Frida is one month
pregnant and that he is leaving her for Frida. Apparently, they
never truly broke up.
13. On November 1, 2014, the Defendant left the family home. He
promised to support the Plaintiff and their three children even
though they are apart and he did until August 2015;
14. On October 2015, the Defendant failed to send money to the
Plaintiff and their children and has not sent any money up until
the filing of this complaint;
15. The Plaintiff took a job as a paralegal at a friend’s law firm but
she still cannot, on her own, support the studies of the three
 children. Andrew Jr. was forced to file a Leave of Absence from
school to work for tuition money and help in sending his younger
siblings to school.
16. Meanwhile, the Defendant, according to family and friends, is
living a luxurious life with Frida and their son, Angelo. The
Defendant earns a fixed monthly income of Three Hundred Fifty
Thousand pesos (PHP 350,000.00); while the Plaintiff is barely
able to provide for herself and their three children. At present, the
Plaintiff is relying on the help of family and friends.
17. On July 5, 2015, Plaintiff filed a complaint for legal separation
against the defendant docketed as RTC-NCR-000123 which is
pending with the Regional Trial Court of Manila.
18. In view of the necessities of the plaintiff and her children, the sum
of One Hundred Fifty Thousand Pesos (PHP 150,000.00) would
be a reasonable amount for the support of the Plaintiff and
theirchildren, pendente lite;
19. Plaintiff, without fault on her part, was compelled to file this
action for separate support, thereby having incurred the sum of
Fifty Thousand Pesos (PHP 50,000.00) by way of attorney’s fees.

PRAYER

WHEREFORE, it is respectfully prayed that:

1. Pendente lite, the Defendant be ordered to pay the Plaintiff the sum
of One Hundred Fifty Thousand Pesos (PHP 150,000.00) per
month;
2. After due hearing on the principal cause of this suit, the Defendant
be ordered to pay the Plaintiff by way of regular support and
maintenance, the sum of One Hundred Fifty Thousand Pesos (PHP
150,000.00), payable on or before the fifth of the month;
3. Plaintiff be granted to recover from the Defendant the sum of Fifty
Thousand Pesos (PHP 50,000.00) for attorney’s fees and the cost
of the suit.

Davao City, February 12, 2020.

ADRIAN PAJARO
Counsel for Plaintiff
Until December 31, 2021
Attorney’s Roll No. 10772
PTR No. 7862245 B; 01-02-20;
Davao City
 IBP O.R. No. 024454; 01-02-20;
Davao City

REPUBLIC OF THE PHILIPPINES)

PROVINCE OF DAVAO DEL SUR) S.S
IN THE CITY OF DAVAO………..)
X…………………………………….X

VERIFICATION AND CERTIFICATION

I, Ching Chong, of legal age, after having been duly sworn in accordance
with law, depose and state that:
1. I am a petitioner in the above-stated case representing the republic
of the Philippines;
2. I caused the preparation of the foregoing petition;
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 true and
authentic records.
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 agency;
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 agency;
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.
IN WITNESS WHEREOF, I have hereunto affixed my signatures this 12 th
day of February 2019, at Davao City, Philippines.

                            
Ching Chong
Affiant

SUBSCRIBED AND SWORN to before me in the City of Davao this

th
30 day of April 2016, by Ching Chong, who has satisfactorily proven her
identity to me through his SSS ID issued by the PRC bearing his photograph
and signature and with VIN 1123-12323232-4, that he is the same person
who personally signed the foregoing document before me and acknowledged
that he executed the same.

WITNESS MY HAND AND SEAL this 12th day of February

2020 in Davao City, Philippines.

NOTARY PUBLIC
Doc. No. 62;
Page No. 13;
Book No. 01;
Series of 2020.