REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
BRANCH ___
CITY OF MANILA

KRISTINE NUMOS,
Petitioner,

-versus- Civil Case No. ____________

For: Declaration of Nullity
of Marriage under Art. 36
of Family Code
JACKIRI NUMOS,
Respondent.
x- - - - - - - - - - - - - - - x

PETITION

Petitioner Kristine Numos, by counsel, unto this

Honorable Court, respectfully alleges:

1. That petitioner Kristine Numos is of legal age, married,

Filipino and resident of 1234 Rosarito St., Sampaloc, Manila;

2. That Respondent Jackiri Numos is likewise of legal

age, married, Filipino and presently residing at 1234 Rosarito
St., Sampaloc, Manila;

3. That petitioner and respondent celebrated their

marriage on January 2, 2000 before the Parish Church of San
Agustin, Manila, certified true copy of their Marriage
Certificate is attached and made integral part hereof as Annex
“A”;

4. That petitioner and respondent have three (3) children.

They have no written agreement executed before the marriage
to govern their property relations nor have any community
property acquired during their marriage. They have no debts;

5. That petitioner met the respondent sometime in 1998

in City of Manila. Their romance culminated in a marriage
before the priest of San Agustin church;

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 6. That in a short span of time they had been together,
this is the time which the petitioner describes as a period
where the respondent’s instability, psychological or otherwise,
showed up;

7. That other instances, wherein such instability could be

reasonably inferred are as follows:

a. After their marriage, the respondent gave up his job

abroad without justifiable reason;

b. That petitioner tried to explain to him that it was

his responsibility to support her but respondent would ignore
and shout at her, making the petitioner the breadwinner of
the family through obtaining loans;

c. That the respondent is a compulsive gambler;

d. He is a womanizer;

e. He resorts to alcohol abuse during their

cohabitation;

f. That parties would fight even for the smallest things

through not due to the fault of the petitioner, and frequently,
the respondent would always apologize to the petitioner, but
later on, he will repeat his quarrelsome and troublesome
ways;

g. He prefers to hang out with friends and with her

flings instead of being with petitioner;

h. Diagnosed of having a Narcissistic Personality

Disorder.

8. That during their honeymoon period, things were

running smoothly between them, but not on the succeeding
week, when the respondent’s instability started to manifest
clearly to the petitioner. The parties separated on August 25,
2014;

9. That some other manifestations of the psychological

and emotional disturbances on the part of the respondent can
be cited as follows:

a. That respondent never respected petitioner’s

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opinion or suggestions as he believed he knew better than her.
For instance, everything was doing well until one day he called
the petitioner and said casually that he was about to have
another child with a woman;

b. That respondent changed quickly from one mood to

another, almost as if he is changing personalities. His temper
became intermittent and even their children were not spared.
On one occasion, the petitioner got severely beaten for coming
home late from a reunion of her wave’s graduation. She got
bruises on her body and a lump on her head

b. That petitioner told the respondent that they should

discuss what went wrong between them and hopefully they
could work it out again. The petitioner verbalized all of the
things she had noticed and felt, knowing that everything
works out when there is an open communication. She told
him about the lack of passion, respect and romance in their
relationship. The respondent just ignored her pleas;

c. That respondent began hurting the petitioner

physically by beating her and shoving her around;

d. That respondent did not stop gambling and using

alcohol;

e. The respondent abandoned the petitioner and left to

be with another woman. Since August 2014, the respondent
did not return nor tried to communicate with the petitioner.
The petitioner on several instances, tried to reach the
respondent through his relatives and friends but to no avail.

10. That the petitioner already gave up on the

respondent after trying to give all her efforts just to save her
marriage to a man who, as shown in the foregoing, is not
cognitive to and psychologically incapable of performing, his
basic marital covenants to herein petitioner;

11. That on August 17, 2019, the petitioner sought help

from Dra. Vicky Belo, MD, a licensed clinical psychologist, for
a psychological assessment.

12. Likewise, on the same above-mentioned date,

respondent was notified with a letter inviting him to undergo
the same procedure that will be conducted to the petitioner,
but to no avail. Attach herewith is a copy of the letter as Annex
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“2”;

13. That on August 17-19, 2019, Dra. Belo conducted the

following tests on the petitioner: House-Tree Test, Human
Figure Drawing Test, OMNI Personality Inventory, SACH
Sentence Completion Test, Sentence-Completion Series-
Marriage, Thematic Apperception Test, 16 Personality Factors
Test, Bender Visual Motor Gestalt Test, Purdue Non-Language
Test, Marital Satisfactory (MSI), and Story Writing. Attach
herewith is a copy of the Psychological Evaluation Report as
Annex “3”;

14. That upon evaluation of Dra. Belo, respondent’s

psychological incapacity from all indications appears to have
been manifesting at the time of the celebration of marriage.
Although said manifestations were not then perceived, the root
cause shall be proved to such an extent that respondent could
not have known the obligations he was to fulfill or knowing
them could not have validly performed them. It is of such
incapacity that respondent was unable to assume his marital
obligations;

15. That the respondent’s incapacity to fulfill his

essential marital obligations appear to be grave, incurable and
deeply ingrained, thus; warranting the issuance of the Decree
of Nullity of petitioner’s marriage with the respondent;

16. That finally, the petitioner has therefore no other

recourse but to seek judicial relief. The prospects or
possibility of respondent to reform and assume his essential
marital obligations is a remote possibility, if not a hopeless
expectancy.

PRAYER

WHEREFORE, it is respectfully prayed that this Honorable

Court rendered judgment:

1. Declaring the marriage entered into by the parties as

NULL and VOID on the ground of psychological incapacity of
the respondent;

2. Ordering the Local Civil Registrar and the National

Statistics Office to cancel in their respective Books of Marriages,

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the marriage between the petitioner and the respondent.

Other just and equitable reliefs are likewise prayed for.

City of Manila, October 19, 2019.

CRUDA & ASSOCIATES

Counsel for the Petitioner
1028 Eloisa St., Sampaloc, Manila

By:

JAN PAUL C. CRUDA

Roll No. 110495
IBP No. 950411/Lifetime/Manila
PTR No. 041195/1-1-19/Manila
MCLE Compliance No. V-1937294
April 27, 2018
Contact No. 09662014808
Email: jpcruda.4@gmail.com

VERIFICATION-CERTIFICATION
ON NON-FORUM SHOPPING

I, KRISTINE PECSON, of legal age, Filipino citizen,

resident of 1234 Rosarito St., Sampaloc, Manila, after having
been sworn to in accordance with law, depose and say:

1. That I am the petitioner in the above-entitled case;

2. That I caused the preparation and filing of the

foregoing Petition;

3. That all the allegations therein are true and correct of

my own knowledge and based on authentic records;

4. That I hereby certify under oath that I have not

heretofore commenced any other action or proceeding
involving the same issues in the Supreme Court, Court of
Appeals or any other tribunal or agency, and that to the best
of my knowledge, there is no other action or proceeding,
which is pending before this Honorable Court, Court of
Appeals, Supreme Court or any other tribunal or agency
involving the same parties and the same issues, and that if I
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learn hereafter that there are other proceedings pending
before this Honorable Court, or any other tribunal or agency, I
hereby undertake to report that fact within five (5) days
therefrom to this Honorable Court.

Manila, Philippines, October 19, 2019.

KRISTINE PECSON
Affiant

SUBSCRIBED AND SWORN to before me this 19th day of

October 2019 at Manila. Affiant exhibited to me her Filipino
Passport No. 12532 issued at Manila.

NOTARY PUBLIC

ATTY. JOSHUA ALANO

Notary Public for and in Manila
Adm. Matter No. 123456 until
December 31, 2020
Roll No. 765432
PTR No. 456321/1-2-19/Manila
IBP No. 567890/1-2-19/Manila
Asturias St., Sampaloc, Manila

Doc. No. _____;

Page No. _____;
Book No. _____;
Series of 2019.