Republic of the PhilippinesREGIONAL TRIAL COURTNational Capital
Judicial RegionManilaBRANCH____
MAE L. ANG Petitioner
- versus -Civil Case No.__________For: Declaration of Nullity of
Marriage
TIM T. ANG
Respondent
x---------------------------------------x
PETITION
PETITIONER, by counsel, unto this Honorable Court, most
respectfully states THAT:1. Petitioner is of legal age, married,
Filipino citizen, and with postal address at 124 Leon Guinto St.,
Malate, Manila, where she may be served with summons and other
court processes of this Honorable Court;
2. Respondent is of legal age, married, Filipino citizen, and
with residence and postal address at No. 49 Estrada St., Malate,
Manila;
3. Petitioner and respondent had been joined in marital union on
January 5, 2002 at Our Lady of the Miraculous Medal in Praaque
City. Copy of the marriage contract is hereto attached as annex
A;
4. The parties lived together as husband and wife until
petitioner slowly discovered of respondents pervasive utter lack of
love, respect and support. The following events and circumstances
led to this case;
4.1 The petitioner and respondent met sometime in September
1999, at Griffith Laboratories in Taguig City, where they were both
employed. They went along well and respondent courted the
petitioner in January 2000, their relationship blossomed into
romance and they become sweethearts;
4.2 They boyfriend and girlfriend relationship at first was good
but problems in their relationship surfaced due mainly to
respondents extreme arrogance and extreme self importance, extreme
lack of sensitivities to petitioner and their marriage, extreme
arrogance and extreme attachment to his family. His failure to make
decisions for himself and his gross dependence to his family when
it comes to decision making;
4.3 When they were about to get married, petitioner broke up
with respondent and she cancelled their wedding because of the
extreme inability of the respondent to decide and make decisions
for himself and their relationship. But thru the repondents promise
to improve, petitioner married the respondent;
4.4 Petitioner, during the course of their marriage, wanted to
assume the role of a submissive wife but respondent did not make
any effort to make decisions for them but nevertheless extremely
defiant to petitioners decision. Respondent entirely depended on
his family for the decisions he will make. Respondent was very
sensitive to criticism, irresponsible, impatient, hot headed and
wanted that all his demands will be complied with immediately,
aside from being severely unfaithfully;
4.5 One time during an office outing in Laguna, she observed
respondent busy texting messages to someone and before they went
home respondent asked petitioner to talk to his officemate and her
husband, it turned out it was a confrontation because he has an
affair with his officemate and that was discovered by her husband.
Petitioner leaned during the confrontation that respondent and the
woman has an extra-marital affairs. To save his face during the
confrontation, respondent directed the petitioner to defend him by
denying for him the said affair in front of the partner of his
other woman;
4.6 Petitioner was so hurt after the confrontation. She wanted
to separate with respondent but respondents family intervened by
deciding for the respondent to resign from work to separate
respondent from his woman. Petitioner gave the marriage another
chance but this time she refrained from having sex with him;
4.7 Respondent remained jobless, maintained a mistress and
remained very dependent on his family. He blamed petitioner for
everything for everything and their relationship was full of rage
and disdain on the part of the respondent;
4.8 Petitioner tried to rebel because of their situation because
the respondent was always bringing out the worse in her. Their
relationship had become worse each day. They separated and when
petitioner wanted to reconcile with respondent, he was nowhere to
be found. Petitioner learned that he was already living with
another woman;
5. In the course of their marriage respondent failed to
discharge the essential marital obligations. He is suffering from
psychological incapacity clinically identified as NARCISSISTIC
PERSONALITY DISORDER which grave, deeply-seated and incurable which
deferred him from appropriately discharging his marital
obligations. This is characterized by jurisdictional antecedence,
as the same existed even prior to his marriage with the petitioner.
A copy of the psychological Report concerning respondents
psychological Report concerning respondents psychological
incapacity is hereto attached as Annex B;
6. The parties have no properties of probable value and
character;
7. The circumstance attendant to the herein party spouses falls
squarely within the provisions of Art. 36 of the Family Code.
PRAYER
WHEREFORE, it is respectfully prayed for unto this Honorable
Court that judgment be rendered declaring the marriage between
herein petitioner and respondent NULL AND VOID under Art. 36 of the
Family Code.
Other reliefs just and equitable under the premises are likewise
prayed for.
City of Manila August 11, 2010.
ATTY JENIFER BALMEOCounsel for the petitionerGround Floor, Unit
II, Commercial Bldg. IIProvincial Capitol Compound, ManilaIBP No.
7777777/ 1.06.10-BulacanPTR No. 143278/ 1.11.10-HagonoyRoll No.
40951MCLE COMPLIANCE No. III-0006465/ 12.02.09
VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING
I, MAE ANG, of legal age, after having been duly sworn in
accordance with law, depose and state that:
1. I am a 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.
___________________________ Affiant
SUBSCRIBED AND SWORN to before me this 11 AUG 2010 in MANILA
affiant exhibiting to me his Community Tax Certificate No.
1111111111 issued on 2 MAY 2008 in the City of Manila.
Doc. No. ;Page No. ;Book No. ;Series of 200_.
