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