REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT OF ________

NATIONAL CAPITAL JUDICIAL REGION
BRANCH _____

__________________________,
Petitioner,
-versus -
CIVIL CASE NO. ________________

__________________________,
Respondent.
xx - - - - - - - - - - - - - - - - - xx

PETITION

NOW COMES the PETITIONER, by her undersigned

counsel, and to the Honorable Court, respectfully alleges that:

I. PARTIES

1.1 Petitioner is of legal age, married, Filipino and with

residence at ______________________________________________
since ___________________.

1.2 As proof of the foregoing, and in compliance with

the requirements of the Guidelines to Validate Compliance
with the Jurisdictional Requirements set forth in A.M. No. 02-
11-10-SC, attached hereto and made integral parts hereof are
the following documents:

a. Sworn certification of residency issued by the

barangay captain of Barangay _______________, marked
as Annex “A”

b. House location sketch, certified by by the barangay

captain of Barangay _______________, marked as
Annex “B”

c. Sworn statement of Petitioner’s undersigned counsel

that said counsel personally verified Petitioner’s
residence at _________________________________________
and that Petitioner has been residing at said address
six (6) months prior to the filing of the instant Petition,
marked as Annex “C”

To
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d. Utility billings in the name of herein Petitioner and at

his above-given address dated six (6) months prior to
the filing of the instant Petition, marked as Annexes
“D” to “D-__”

e. Government-issued ID of herein Petitioner bearing his

name and his above-given address - the issuance of
said ID being six (6) months or more prior to the filing
of the instant Petition, marked as Annex “E”

1.3 Respondent is likewise of legal age, married, Filipino

and may be served with summons and other processes of this
Court at his last known address in ______________________.

II. STATEMENT OF THE FACTS

2.1 xxx

2.2 xxx

2.3 xxx

2.4 xxx

2.5 xxx

2.6 xxx

2.7 xxx

2.8 xxx

2.9 xxx.

2.10 xxx

2.11 xxx

2.12 xxx

2.13 xxx

2.14 xxx

2.15 xxx

2.16 xxx
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2.17 xxx

2.18 xxx

2.19 xxx

2.20 xxx

2.21 xxx

2.22 xxx

2.23 xxx

2.24 xxx

2.25 xxx

2.26 xxx

2.27 xxx

2.28 xxx

2.29 xxx

2.30 xxx

2.31 Petitioner, intent on seeking a declaration of nullity

of her marriage to the Respondent, has submitted herself to
psychological evaluation by a competent and licensed
psychologist who, after interviewing her as well as two
supporting witnesses who know the Respondent, came up
with a psychological evaluation of the Petitioner as well as an
clinical impression of the Respondent in which it was
established that:

a. Petitioner is not suffering from any permanent and

incurable psychological incapacity

b. Respondent is suffering from a psychological disorder

– ___________________ – which disorder was present
even before marriage

c. Respondent’s psychological disorder – which is severe

and incurable – prevented him from complying with
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the essential marital obligations of marriage at the

time of the celebration of marriage and even until now.

2.32 A copy of the psychological evaluation of the

Petitioner and the clinical impression of the Respondent is
attached hereto marked as Annex “F” and made an integral
part hereof.

2.33 As proof of their marriage, attached hereto marked

as Annex “G” is a certified true copy of their Certificate of
Marriage.

2.34 Parties have ___ child/children, as evidenced by

copies of the Certificate of Live Birth of said child/children,
wshich copies are marked as Annex “H” to “H - __” and
made an integshe parties have no properties – personal
part/parts hereof.

2.35 Parties have no property -real or personal - that

they have amassed in common prior to their estrangement.

III. SOLE CAUSE OF ACTION

Herein Petitioner reiterates all the foregoing and alleges

as her sole cause of action that:

3.1 It having been established that Respondent has

been - and still is - suffering from an severe and incurable
psychological disorder that prevents him from complying with
the essential marital obligations at the time of the celebration
of marriage, a declaration of nullity his marriage to the
Petitioner is proper and warranted.

PRAYER

WHEREFORE, above premises considered, it is

respectfully prayed of the Honorable Court that – after due
hearing - judgment be rendered declaring the marriage
between the Petitioner and Respondent as null and void,
Respondent being psychologically incapacitated to comply with
the essential marital obligations of marriage at the time of the
celebration thereof.

Petitioner prays for . . .

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. . . other just and equitable measures of relief.

Las Pinas City. _____ August 2019.

_____________________________
Counsel for the Petitioner
Roll of Attorney’s No. ____________
PTR No. __________/_______/_____
IBP Lifetime Member OR No. _________/_______/_____
MCLE Comp. No. ________________/___________
________________________________________
________________________________________
Tel. No.: _________________ email: ____________________

VERIFICATION AND
CERTIFICATION OF NON-FORUM SHOPPING

I, ________________________, under oath, hereby depose

and state that:

1. I am the petitioner in the instant petition;

2. I have caused the preparation of the foregoing

Petition, the contents of which I have read and understood,
and the same are true and correct of my own personal
knowledge and/or based on 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, there is no
such other pending action or claim; and

4. Should I thereafter learn that the same or similar

action or claim has been filed or is pending before the
Supreme Court, Court of Appeals, or any other court,
tribunal or quasi-judicial agency, I undertake to report such
fact before this Court within five (5) days from knowledge or
notice thereof.
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IN WITNESS WHEREOF, I have hereunto set my hand

this ____ day of August 2019 in ____________________.

___________________________________
Affiant

SUBSCRIBED AND SWORN to before me this _____ day

of August 2019 in ________________, affiant exhibiting to me
his government-issued ID __________________ issued on
________________ at ________________.

Notary Public
Doc. No. ___
Page No. ___
Book No. ___
Series of 2019.