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7/28/2019 1. Petition
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REPUBLIC OF THE PHILIPPINES
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
BRANCH 13, BATAC CITY
ILOCOS NORTE
IN THE MATTER OF THE PETITION
FOR THE DECLARATION OF NULLITY
OF MARRIAGE BETWEEN BANGS GARCIA-GARRIDO
AND PAUL DANILO GARRIDO
BANGS GARCIA-GARRIDO
Petitioner,
Civil Case #
-versus-
PAUL DANILO GARRIDO
Respondent,
x--------------------------------------------x
PETITION
Petitioner, thru counsel, and unto this Honorable Court, most respectfully
alleges that:
1. Petioner is a Filipino, of legal age, married to Respondent, and a residentof Brgy. Billo-ca, Batac City, Ilocos Norte whereas Respondent is a Filipino,
of legal age, married to Petitioner, and a resident of Brgy. Puruganan
Dingras, Ilocos Norte, where addresses may be served with summons and
other court processes;
2. In 2007, petitioner and respondent were co-instructors at the College ofCriminal Justice Education, Northwestern University. At first, petitioner was
not interested in respondent considering his snobbish gestures towards the
former. Petitioner only became attracted to respondent after theyhappened to sit beside each other in a passenger jeep;
3. Respondent courted petitioner even though petitioner already had a boyfriend. Later on, when respondent discovered petitioners other
relationship, the former demanded more time and attention which
petitioner appreciated recalling it like a child longing for love, time and
attention;
4. Respondent visited petitioner in their house frequently. These adorableactuations of the former eventually led to a romantic affair. Not for long,
their secret liaison resulted in sensual intimacies, not once, but on several
times. These intimate moments that petitioner and respondent shared
together in the private perfumed parlor, so to speak, resulted in the
unexpected pregnancy of the former. This turn of events changed their
lives forever;
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5. The families of both petitioner and respondent agreed that since theywere gainfully employed, they should now tie the knot for the sake of their
soon-to-be offspring and transformed their amorous relationship into a
marital bliss. Needless to say, Petitioners pregnancy hastened the ir
marriage that was held on 10 May 2008 in St. Joseph Church, Dingras,
Ilocos Norte with Reverend Father Winchael Ganal as solemnizing officer.A copy of their marriage certificate is attached as Annex A and made
an integral part hereof;
6. Living together as husband and wife, their marriage was blessed with 1child. Petitioner gave birth to their first baby Juan Carlos Garrido on 25
December 2008.
7. The first stages of their married life were full of happiness and excitement,however as years went by, a gradual change, in what seemed to be a
happy union, loomed in the horizon. Respondent asked petitioner to goabroad supposedly because their incomes were not enough, but much to
the opposition of the petitioner. Petitioner did not like the idea of either
her or her husband going abroad to earn more money at the expense of
the family being separated. But due to respondents insistence, petitioner
eventually gave in to his wish and flew to Dubai as an overseas worker in
14 February 2009. The latter worked there as a Cashiers Clerk. Certificate
of her employment is attached as Annexes B and made an integral part
hereof;
8. Petitioner endured working hard in the tremendously hot climate of Dubaifor two years while sending money religiously to respondent and the child;
9. At first, they communicated constantly through texting and phone callsbut subsequently petitioner noticed a sudden change of respondents
behavior, his regular texts and phone calls became far and infrequent.
There were also times when respondent would simply drop the call without
reasons. On certain occasions when she would call him late at night, he
was not still in the house and nowhere to be found. And whenever they
would finally talk on the phone, respondent was always in a hurry to stop
the conversation arguing that the international calls was expensive.
Making the situation far worse, respondent even prevented their childfrom talking to her on the phone. But to the biggest surprise of petitioner,
respondent told her that he wanted to call their marriage quits;
10.On 9 March 2011, Petitioner went home to the Philippines withoutrespondents knowledge in order to find the real score and hope to save
their marriage. However, on 12 March 2011 to her surprise, the former
found out that the latter had developed a more than intimate relationship
with another woman in LIZETTE COLOMA, her co-employee at
Northwestern University, whom she witnessed them, not once but twice
holding their hands, also kissing and hugging each other at the Aurora
Park, Laoag City. In his first caught, petitioner did not confront him. But on
the second consummation there she confronted respondent. Petitioner
then confronted respondent of such instance. Though despite the
formers efforts to discuss the matter with the latter, respondent slapped
the peititioner while saying the words naim-imas suna ngem sika!(she is
more delicious than you!) and just left her; a copy of the photograph of
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respondent and LIZETTE COLOMA intimately together is attached as
Annex C and made an integral part hereof;
11.Despite her success at Dubai, petitioner is now psychologically disturbedthereby prompting the services of Dr. Rilan Reyes, clinical psychologist,which the latter revealed that petitioner is suffering from "Antisocial
Personality Disorder," characterized by a pervasive pattern of social
deviancy, rebelliousness, impulsivity, self-centeredness, deceitfulness and
lack of remorse. The report also revealed that petitioners personality
disorder is rooted in deep feelings of rejection starting from the
shortcomings and infidelity of the respondent. It was Dr. Rilans conclusion
that petitioner is psychologically incapacitated to perform his marital
obligations; a copy of her Psychological Report is hereby attached as
annex D and made an integral part hereof;
12.Considering the acts of the respondent as well as the psychologicalreport, petitioner is then psychologically incapacitated to comply with the
marital obligations of marriage for failing to live together with the
petitioner, observe mutual love, respect and fidelity, and render mutual
help and support;
13.No property , real or personal, was acquired by petitioner and respondentduring their union;
PRAYER
WHEREFORE, petitioner most respectfully prays to this Honorable Court that
after due notice and hearing, judgment be rendered declaring the marriage
between petitioner and respondent 10 May 2008 VOID AB INITIO.
Other reliefs just and equitable in the premises are likewise prayed for.
Laoag City, for Batac City, Ilocos Norte, Philippines, 12 June 2011.
ATTY. JEREMIAS BITANGA
For the Petitioner
Rm 101, DECS Building, Laoag City
PTR No. 001-01-03-2011, Laoag City
IBP No. 00001-01-03-2011,Laoag City
Roll of Atty. No. 101101
MCLE Compliance Cert. No. 001-0000-01-10-2011
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VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING
I, BANGS GARCIA-GARRIDO, of legal age, married to above-stated
Respondent, and a resident of Brgy. Billo-ca, Batac City, Ilocos Norte, under
oath, hereby depose and state that:
1. I am the petitioner in the above-entitled case;2. I have caused the preparation and filing of the foregoing Petition;3. I have read and understood the allegations therein contained and the
same are true and correct of my knowledge;
4. I have not heretofore commence or filed any other action involving thesame issues in any court, tribunal or agency; that to the best of my
knowledge, no such action is pending in any court, tribunal or agency;that should I hereafter learn of any such pending action, I undertake to
inform this Honorable Tribunal of such fact within five (5) days therefrom.
IN WITNESS WHEREOF, I have hereunto set my hand this 12th day of June,
2011, Laoag City.
BANGS GARCIA-GARRIDO
Affiant
SUBSCRIBED AND SWORN to before me this 12th day of June, 2011, affiant
exhibiting to me her SSS ID# 23567 issued on the 8th day of June, 2000 at Laoag
City.
WITNESS MY HAND AND NOTARIAL SEAL on the above stated date and
place.
ATTY. FERDINAND MENDOZA
Notary Public for Laoag CityCommission Serial No. 1234
Until Dec. 31, 2011
Santos Bldg., Ablan Ave., Laoag City
Roll No. 2234
PTR No. 2234/Laoag City/01.05.2011
IBP No. 2234/Laoag City/01.05.2011
MCLE Compliance Cert. No. 00099-
09092009
Doc. :
Page :
Book :
Series of 2011