Republic of the Philippines

REGIONAL TRIAL COURT

13TH Judicial Region
BRANCH 9
Bulwagan ng Katarungan

ANGELINA JOLIE CIVIL CASE No.:

Petitioner,

FOR:
- versus -
DECLARATION OF NULLITY OF
MARRIAGE UNDER ARTICLE
36 OF THE FAMILY CODE.
BRAD PITT,
Respondent,

x- - - - - - - - - - - - - - - - -x

PETITION

COMES NOW, Petitioner, through the undersigned counsel,

unto this Honorable Court, most respectfully avers that:

1. Petitioner is of legal age, married to respondent BRAD

PITT, and with permanent address at Brgy. Balinsasayao, Abuyog,
Manila where she may be served with summons, notices and other
processes of the Honorable Court;

2. Respondent is also of legal age, married to petitioner

ANGELINA JOLIE, and a resident of 454, Plaridel St., Barugo,
Manila where he may be served with summons, notices and other
processes of the Honorable Court;

3. Both petitioner and respondent have the capacity to sue

and be sued;
 4. Before they got married in civil rites on 24 July 2008 in
Manila Cathedral, Manila, petitioner and respondent got acquainted
with each other sometime in February, 1999 in a videoke bar in
Carigara, Leyte where petitioner was a walk-in customer with some
friends while respondent was working as a waiter in said videoke bar.
Petitioner and respondent got acquainted with each other during that
first meeting. Petitioner asked respondent if it would be alright for
him if he took him out after his work. Respondent agreed with
petitioners request;

5. After his work, petitioner and respondent checked inside a

lodging house situated near the videoke bar where respondent work.
While inside, respondent took out a bottle of Ginebra San Miguel
where he said he got from the bar and offered it to petitioner. After
having three shots of the liquor, petitioner felt dizzy and lied down on
the sofa;

6. Thereafter, petitioner can barely recall what transpired

between her and respondent inside the lodging house. The next day,
she was surprised when she woke up inside an unfamiliar place. After
regaining her consciousness, she got out of the lodging house and
went home;

7. After two months, petitioner, accompanied by a friend,

went to respondents house to inform him that something had
happened between them inside the lodging house. She also told
respondent that she is pregnant because of what happened and
feared that if her parents discover her situation they might kill her.
Confused, respondent told his parents of his ordeal and asked them
on what to do. His parents advised him to marry petitioner in order
to avoid scandal;
 8. The couple got married in civil ceremonies sometime on
24 July 2008 before Officiating Priest Rodrigo de la Serna of Manila
Cathedral, Manila. Copy of the Certificate of Marriage is hereto
attached as Annex A and made an integral part hereof;

9. Petitioner and respondent lived with petitioners parents as

respondent quits his job and petitioner was still in college. They
depended for support entirely from petitioners parents.

10. It was during that cohabitation that petitioner sensed

something wrong in respondents behavior. Respondent would often

get mad whenever he arrives home late and is not immediately
attended to by petitioner. There was a time when petitioner was
having a drinking session with his friends inside their house that
respondent went berserk and told his friends to go home.
Respondent got mad for the flimsy reason that petitioner failed to
immediately attend to her.

11. Sometime in January 2012 during the fiesta celebration of

their place while petitioner and her friends were having a drinking
session, a boyfriend of petitioners friend arrived and joined them in
their drinking. That boyfriend of her friend did not stay long as
respondent became jealous, accusing that petitioner was the one
whom that man went to their house for and not her friend. So
petitioner requested his friends to leave as respondent was already
making trouble due to jealousy. After her friends left their house,
respondent quarreled petitioner vigorously so she decided to evade
trouble by going to bed.

Petitioner was shocked when moments later, respondent

followed him to the bedroom and with a knife in his hand, suddenly
attacked petitioner with a stab blow. Fortunately, petitioner was able
to evade respondents stab and was able to grab the knife. In order
to avoid trouble, petitioner left the house and stayed in his
grandparents house. That had been the situation as respondent
would always cause trouble for the flimsiest reason, mostly on
baseless jealousy.

Such attempts against petitioners life were repeated on two

more instances, even when the petitioner is pregnant, always on
baseless jealousy and other flimsy causes that were more imagined
than real.

Petitioner thought that respondents attitude will change after

the birth of their third child. Unfortunately, even after the birth of
their son on March 5, 2012 their troublesome situation persisted as
respondent remained quarrelsome, causing trouble even more. At
times when petitioner would not have sexual intercourse with
respondent as petitioner is tired from school, respondent would get
mad and baselessly accuse petitioner of having an affair with other
men. In order to avoid trouble and getting quarreled by respondent,
petitioner would always oblige and fulfill the whims and caprices of
respondent. That situation led them to having three children as no
amount of control by petitioner could be done for respondent had
that high orgy and would quarrel petitioner if unmet;

12. Petitioner and respondent begot three children, the first

child named CHELSEA PITT was born on 25 November 2008; the

second child named BEATRICE PITT was born on 10 October 2010;
the third child named WILLIAM PITT was born on 26 March 2012.
Copy of the Certificates of Live Birth of their three children are hereto
attached as Annexes B, C, and D and made integral parts
hereof;
 8. Petitioner was employed with the Philippine National
Police on October 2013 and was assigned at Mahaplag Police Station;

9. Lately, respondent committed another attempt against

the life of petitioner inside their house. The incident occurred on
November 23, 2013 when respondent shot petitioner with a 45
caliber pistol in front of their children whereby petitioner was hit on
her foot. Copy of the spot report is hereto attached as Annex E and
made an integral part hereof;

10. Since that shooting incident in 2013, petitioner decided to

live separately from respondent, fearing for her safety as respondent
had manifested his criminal inclination against the life of petitioner. It
created an indelible mark in petitioners mind over a constant fear of
a continuing threat upon her life as respondent is a potential criminal
who can strike anytime;

11. When petitioner would confront respondent about his

unpleasant attitude and behavior, respondent would become violent,
shouting at petitioner with dirty attacks and engaging in verbal abuse
so humiliating and embarrassing to petitioner as respondent would
do it in public and in front of many people;

12. After the marriage ceremony, petitioner expected to have a

happy life with the respondent hoping that she will change his
behavior and attitude for the better, showing and observing mutual
love, respect, and fidelity and render mutual help and support in
happy companionship and feeling secure that they will learn to live in
harmony and peace with each other and with their children.
However, to petitioners dismay and frustration, respondent had been
and still is psychologically incapacitated to comply with the essential
marital obligations;

13. Petitioner found to her great shock and dismay that

respondents quarrelsome attitude turned from bad to worse, causing
trouble and disharmony in their marriage. Petitioner was so much
hurt and devastated after the several attempts by respondent upon
her life, the latest being the most fatal and life threatening as she
was hit with a gunshot aimed on the vital part of his body on her
foot;

14. Since petitioners discovery of respondents true person of

being violent who was prone to physically abuse petitioner and his
being an incorrigible troublemaker and quarrelsome person,
respondent willfully failed to perform his marital obligations and for
all intents and purposes does not consider her as his wife anymore.
Petitioner now sues respondent for the declaration of the nullity of
the marriage under Article 36 of the Family Code, as respondent
at the time he contracted marriage did not have the intent to perform
his marital obligations to the petitioner under Article 68 of the same
Code. As a matter of fact, immediately after their marriage,
respondent exhibited and manifested by overt acts and behavior that
he was psychologically incapacitated to comply with the essential
marital obligations. The psychological incapacity was present at the
time of the celebration of the marriage, although the same became
manifest only thereafter, and thus, the marriage can be nullified
under Article 36 of the Family Code;

Petitioner tried everything possible to persuade respondent to

change for the better and leave his violent personality so that they
could build their family and live together and establish a happy
family, fulfill their marital vows and discharge their reciprocal
obligation to consummate the essential duties of their union and in
order that their marriage will prosper to a happy family life but all
such pleas by petitioner were unheeded as respondent was in a
paranoia of living a violent life. Respondent was not ready to take the
responsibilities and was not prepared to live in a harmonious and
peaceful union with petitioner;

15. Respondents violent behavior and killer-instinct are clear

signs of psychological incapacity. Respondents odd behavior
demonstrates a severe insensitivity and inability to give meaning and
significance to the marriage. It is very well to stress that one of the
essential marital obligations is to support each other under a mutual
love of a happy family life;

16. Respondents act affirms his adamant willful refusal to

take the marital obligations of establishing a happy family.
Respondents act is indicative of a hopeless situation and a serious
personality disorder which is a clear manifestation of his incapacity to
fulfill the obligations of her marriage vows which requires the
essential duties to live together, observe mutual love, respect, and
fidelity and render mutual help and support;

17. Petitioner, realizing that she is growing older day by day,

decided not to prolong his agony by filing this petition to nullify her
marriage with respondent, which marital life had long deteriorated
and broken into pieces;

18. Ever since petitioner never fell in love with respondent and
her life was always in hellish trouble under imminent danger and
threat from a violent man with killer instincts;
 19. Before the filing of this petition, petitioner had exerted
earnest efforts for possible reconciliation with respondent but the
same went all for naught.

PRAYER
WHEREFORE, premises considered, it is most respectfully
prayed of this Honorable Court that judgment be rendered:

1. Declaring the respondent BRAD PITT psychologically

incapacitated to comply with the essential marital obligations
pursuant to the provisions of Article 36 of the Family Code;

2. Declaring the nullity of the marriage between petitioner

ANGELINA JOLIE and BRAD PITT for being void ab initio on the
ground of psychological incapacity on the part of the respondent in
accordance with Article 36 of the Family Code;

3. Allowing the petitioner to revert to his civil status as

SINGLE;

4. Other reliefs just and equitable under the premises are

likewise prayed for.

SO PRAYED.
Barugo, Manila, Manila City. 05 February 2014.

ATTY. DON A. DEHAYCO

Counsel for the Petitioner
#45 Burgos St., Barugo, Manila
Roll of Attorneys No. 12345
PTR No. 1398649 01/10/08
IBP No. 671008 06/28/02
Lifetime Roll No. 54445
MCLE Compliance No.II-0046869
Copy furnished:

OFFICE OF THE SOLICITOR GENERAL

Office of the Solicitor General
134 Amorsolo Street, Legaspi Village, Makati City
Republic of the Philippines)
Barugo, Manila )S.S.

COMBINED VERIFICATION WITH CERTIFICATION OF NON

FORUM SHOPPING

I, ANGELINA JOLIE, subscribing under oath, hereby deposes

and states that:
1. I am the petitioner in the instant case;

2. I have read the foregoing Petition and the allegations therein

are true and correct;

3. I attest to the authenticity of the annexes thereto;

4. I have not commenced any other action or proceeding

involving the same issues in the Supreme Court, Court of Appeals, or
different Divisions thereof, or any other tribunal or agency;

5. No such action or proceeding is pending in the Supreme

Court, the Court of Appeals, or different Divisions thereof, or any
other tribunal or agency;

6. If I should learn that a similar action or proceeding has been

filed or is pending before the Supreme Court, the Court of Appeals,
or different Divisions thereof, or any other tribunal or agency, I
hereby undertake to notify this Honorable Court within five (5) days
from such notice.

ANGELINA JOLIE

SUBSCRIBED and SWORN, to before me this 5TH day

of February 2014 in Barugo, Manila. The affiant exhibiting to me his
SSS No. N26-01-004190 issued by Social Security System, on May
12, 2001, and Community Tax Certificate No. 32354455 issued
on November 30, 2010, at Barugo, Manila.
 ATTY. DON A. DEHAYCO
Notary Public for Barugo, Manila
#45 Burgos St., Barugo, Manila
Appointment No. 25 Until Dec. 2015
Roll of Attorneys No. 12345
PTR No. 1398649 01/10/08
IBP No. 671008 06/28/02 Lifetime
Roll No. 54445
MCLE Compliance No.I-0027464
MCLE Compliance No.II-0046869

Doc. No. 1
Page No. 2
Book No. 3
Series of 2011