Republic of the Philippines

REGIONAL TRIAL COURT

12th Judicial Region
Branch 2, Iligan City

JOSEFINA LOISA F. ANDALIO

Petitioner,

- versus - Civil Case No. 0205

For: Legal Separation

RONNIE A. ALONTE II
Respondent.
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PETITION FOR LEGAL SEPARATION

Petitioner, through counsel, an unto this Honorable Court, respectfully

alleges:
1. That petitioner is a resident of Bliss Project, Biga, Lugait,
Misamis Oriental, Philippines;

2. That petitioner and the respondent were legally married in the

parochial church of the Diocese of Lugait on February 15, 2013;

3. That out of said marriage, two (2) children were born, to wit:
Alexa A. Alonte, born on December 12, 2013; and Andrew John A. Alonte,
born on February 24, 2016;
 4. That during the said marriage, the following properties had been
acquired: a residential house and lot located in Bliss Project, Biga, Lugait,
Misamis Oriental, constituted as family home and registered in both the
names of petitioner and respondent with Transfer Certificate of Title No. LT-
33054 and recorded with the Registry of Deeds of Misamis Oriental; and a
Sedan-type automobile manufactured by Toyota Motors Corp. with Chassis
Serial No. 5YJSA1DG9DFP14705 and Plate No: RB – 08257 and registered
with the Land Transportation Office of Iligan City;

5. That on or about the period from January 23, 2017 and February
25, 2017, the respondent committed an act of Concubinage as defined in the
Revised Penal Code, for which he was convicted by the Regional Trial Court
of Iligan City in Criminal Case No. 024569 on December 5, 2018, judgment
of which had already become final;

6. That the petitioner has never condoned or committed such act of

Concubinage on the part of the respondent;

7. That the facts of this case render the reconciliation of the parties
highly improbable.

WHEREFORE, it is respectfully prayed:

(a) That pending this legal separation proceeding, the respondent

be deprived of his right to manage the conjugal partnership and that the
adequate provision be made out of the conjugal property for the care and
support of the minor children, Alexa A. Alonte and Andrew John A. Alonte;

(b) That after due hearing, a decree of legal separation be issued by

this Honorable court, ordering: (1) That the petitioner be entitled to live
separately from the respondent, without dissolution, however, of the
marriage bond; (2) That the conjugal partnership be dissolved and liquidated,
depriving the respondent from his share of the conjugal partnership profits
and awarding the same to the above-named children; (3) That the custody
of the minor children be awarded to the petitioner; and

(c) That such other reliefs just and equitable be granted.

City of Iligan, Philippines, April 10, 2019.

ATTY. WILLIAM Y. DAUG

Counsel for the Petitioner
Commission Serial No. 97583
Until December 31, 2020
Roll of Attorney No. 10864
IBP No. 1256/Jan. 3, 2018/Iligan City
PTR No. 08533/Feb. 1, 2018/Iligan City

VERIFICATION AND CERTIFICATION

OF NON-FORUM SHOPPING

REPUBLIC OF THE PHILIPPINES)

City of Iligan ) S.S.

I, JOSEFINA LOISA F. ANDALIO, Filipino, of legal age, and residing

at Bliss Project, Biga, Lugait, Misamis Oriental, after having been sworn to
in accordance with law, deposes and says that:

1. I am the Petitioner in the above-entitled case;

2. The facts stated in the above complaint are true and correct to the best
of my knowledge and authentic records;
 3. I have not commenced any action or filed any claim involving the same
issues in any court, tribunal or quasi-judicial agency and, to the best of
my knowledge, no such other action or claim is pending in them, and
4. If I should learn that the same or similar action or claim has been filed
or is pending after its filing, I shall report that fact within five (5) days
from notice to the court or where the complaint or initiatory pleading
has been filed.

IN WITNESS WHEREOF, I have hereunto set my hand this 10th day

of April 2019 at the City of Iligan, Philippines.

JOSEFINA LOISA F. ANDALIO

Petitioner

SUBSCRIBED AND SWORN to before me this 10th day of April 2019 at the
City of Iligan, Philippines by petitioner Josefina Loisa F. Andalo with Passport
No. XR-439201, issued on December 13, 2017 at the Department of Foreign
Affairs - Cagayan de Oro Branch.

ATTY. REY T. PUNO

Notary Public
Commision Serial No.085432
Until December 31, 2020
Roll of Attorney No. 56978-2012
IBP No. 908753-2/13/2012
PTR No. 324685-2/13/2012
MCLE Compliance III No. 123475
Issued on July 5, 2012