REPUBLIC OF THE PHILIPPINES )

CITY OF MANILA )
S.S.

Republic of the Philippines

REGIONAL TRIALCOURT
Third Judicial Region
Branch 18
Malolos, Bulacan

RACHEL GREENE GELLER

Plaintiffs,

Versus Civil Case No. 123

ROSS GELLER, Defendant.

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COMPLAINT

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

respectfully avers that:

1. The Plaintiff is a resident of Lot 08 Blk 76 Maria Ramona

Subdivision, Baliuag, Bulacan.

2. The Defendant is a resident of Lot 02 Blk 75 Carmell Subdivision,

Balagtas, Bulacan.

3. The Plaintiff and the Defendant, are wife and husband,

respectively, having been married in Bulacan on February 14,
1996;

4. The Plaintiff was pursuing medicine when the Defendant

proposed and they get married. The Plaintiff hesitated at first
as she wanted to finish her medical school but the Defendant
said that nothing will change after the marriage, that she can
continue her medicine 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 medical school to take care
of their children;
5. During the marriage, three children were born namely:
a. Emma Geller (EMMA) born on January 29, 1997;
b. Ben Geller (BEN) born on October 12, 2000; and
c. Penelope Geller (PENELOPE) born on February 14, 2004;
d.
6. During the marriage, the Defendant was able to establish his
own construction business named, Geller Construction
International which blossomed into one of the most well
known construction business in the country;

7. 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, Phoeby Buffay (Phoebe) . The Plaintiff
dismissed the stories as mere rumors;

8. On February 14, 2015, Valentine’s Day, their 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, 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.

9. Plaintiff confronted the Defendant about his illicit affair. The

Defendant confessed that he had been having an affair with
Phoebe since December 2013. The Plaintiff wanted to separate
with the Defendant right there and then, but the Defendant
begged for forgiveness. She decided that, for the children, she
should stay with him.

10. Their relationship never returned to normal and on October 24,

2015, the Defendant informed the Plaintiff that Phoebe is one
month pregnant and that he is leaving her for Phoebe.
Apparently, the defendant never truly severed his relationship
with Phoebe while they were supposed to fix their relationship.
 11. On November 1, 2015, 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 2016;

12. 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;

13. The Plaintiff took a job as a medical technologist but she still
cannot, on her own, support the studies of the three children.
Emma was forced to file a Leave of Absence from school to
work for tuition money and help in sending his younger
siblings to school.

14. Meanwhile, the Defendant, according to family and friends, is

living a luxurious life with Phoebe 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.

15. 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 Bulacan.

16. 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 their children, pendente lite;

17. 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.

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.

City of Manila, March 8, 2018.

ATTY. MICHAELA DE GUZMAN

Roll No. 10908
IBP Lifetime Membership No. 09876
MCLE Compliance No. VI - 0018/05-14-
2015

VERIFICATION & CERTIFICATION AGAINST FORUM

SHOPPING

I, RACHEL GREENE, of legal age, after having been duly sworn

in accordance with law, depose and state that:
1. I am the plaintiff in the above-stated case;
2. I caused the preparation of the foregoing complaint;
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 of copies of documents and records in my possession;
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.

RACHEL GREENE-GELLER
Affiant
 SUBSCRIBED AND SWORN TO, before me, in the City of
MALOLOS, BULACAN on this 8TH day of MARCH 2018, affiant
exhibiting before me her SSS ID No. CC-34657235 issued on
MARCH 5, 2016 at BULACAN. PHILIPPINES.

SANTOS-DIMAYUGA LAW FIRM

By: Atty. Andrea Santos
Roll No. 272765
IBP Lifetime Membership No. 09865
MCLE Compliance No. VI – 00165/05-14-2017

Doc. No. 5;
Page No. 34;
Book No. 3;
Series of 2016.

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