Petition

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 # -versusPAUL 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 resident of 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 of Criminal 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 they happened to sit beside each other in a passenger jeep; 3. Respondent courted petitioner even though petitioner already had a boy friend. 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 adorable actuations 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;
5. The families of both petitioner and respondent agreed that since they were 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 1 child. 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 go abroad 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 Dubai for two years while sending money religiously to respondent and the child; 9. At first, they communicated constantly through texting and phone calls but 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 child from 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 without respondents 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
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 disturbed thereby 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 psychological report, 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 respondent during 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
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 the same 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 City Commission 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. 0009909092009 Doc. Page Book Series : : : of 2011

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REPUBLIC OF THE PHILIPPINES FIRST JUDICIAL REGION REGIONAL TRIAL COURT BRANCH 13, BATAC CITY ILOCOS NORTE

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