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PETITION
COMES NOW plaintiff, by the undersigned counsel and unto this
Honorable Court, most respectfully alleges:
1. Plaintiff is of legal age, Filipino citizen and a resident of 143
Lonely Hearts St., Bacolod City while respondent is likewise of
legal age, Japanese citizen and a resident of Door No. 343, Suzaku
Apartments, Kiyamachi Street, Kyoto City, Japan, where he may
be served with summons, orders and other legal processes of this
Honorable Court;
2. Plaintiff and respondent are husband and wife, having been legally
married on December 12, 2007 at Hiroshima, Japan and
5. To end her grieving process for the death of her first husband,
plaintiff decided to take a vacation to Japan. During said vacation,
a friend of hers suggested a job opening in a well-known electronic
company. Petitioner decided to submit the required documents as a
walk-in applicant for the position.
6. After having been accepted for the job, plaintiff was given a
working visa in Japan and commenced her employment with the
said electronic company.
reluctant and hesitant to consummate the marriage and that he senselessly and constantly
refuse to have any sexual relations with her. The respondent's unreasonable refusal amounted
to a psychological incapacity to comply with the essential marital obligations.
15. The petitioner further states that respondent became close to one of his male clients. That on
November 25, 2009 petitioner saw respondent's car parked in a famous restaurant and
thereafter saw respondent holding hands with another man which happens to be the
respondent's client in one of his businesses and publicly displaying their affections with each
other. A copy of the photograph is hereto attached as Annex E;
16. On December 22, 2009 petitioner received a package or mail addressed to the name of the
respondent which was delivered in their residence in Bacolod City. The same package
contained love letters from the said man whom the respondent had an affair with. A copy of
the receipt and acknowledgement of the mail are hereto attached as Annex F and Annex
G
17. Respondent's psychological condition was the compelling cause and reason of his refusal to
consummate the marriage and renders him incapable of complying with the essential marital
obligations of a husband. Such manifestation of the psychological condition is grave,
incurable and existed even prior the marriage of petitioner and respondent.
18.
irresponsible and continually failed to adapt himself to married life and perform the essential
responsibilities and duties of a husband.
VERIFICATION
01.
That I am the plaintiff in this case and that I have caused the
shopping, I hereby certify that: a) I have not commenced any other action
or proceeding involving the same issues before the Supreme Court, or Court
of Appeals, or any other tribunal or agency;
b)
to the best of my
INA GRABYADO-MO
Affiant
affiant
exhibited
to
me
his
______________
dated