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REPUBLIC OF THE PHILIPPINES REGIONAL TRIAL COURT FIRST JUDICIAL REGION BRANCH_______

Plaintiff, -versusDefendant. x-------------------------------------------------x

FAMILY COURT CASE NO.______ for DECLARATION OF NULLITY OF MARRIAGE

PETITION PLAINTIFF, through undersigned counsel, unto this Honorable Court, most respectfully states that: 1. She is of legal, Filipino and presently residing at _____----. 2. Defendant is also of legal age, Filipino and presently with address at____________where he may be served with summons and other court processes;

3. The parties entered into marriage on ____at___________, a copy of their Marriage Contract is herein attached as Annex A; 4. They have a child named,_________________, a copy of the birth certificate is herein attached as Annex B; 5. The petitioner and respondent met at ___________located along______________; 6. Their courtship began ____________and would spend together often such that they would seek each others company in the confines of more private quarters; 7. Consequently, petitioner became pregnant after a year and on __________, petitioner gave birth to their first child; 8. During the marriage, respondent got emotionally involved with so many ladies on different occasions and were caught by sympathetic friends which were relayed to petitioner. Because of the possible clash that may ensue and lacking in guts to confront the respondent, petitioner opted to keep silent about it; 9. Eventually, petitioner confronted the respondent and admitted his extra marital affairs with different women. After a few months, for her own personal and selfish

reasons, petitioner wanted respondent all to herself and not to lose the father of her child but unknowingly, this action of petitioner did not at all change the character of the respondent and instead indulge in his vices, like gambling, drinking and womanizing; 10.At the time petitioner and respondent entered into marriage, both were laboring under extreme psychologically incapacities which can be medically and psychologically proven and identified and which manifestations of psychological illness were not perceivable at the time of marriage but has fully manifested itself during their marriage; 11. The incapacity of both petitioner and respondent are of such grave and serious nature, permanent and incurable which brought about their inability to assume the essential marital obligations embraced under Articles 68 to 71 of the Family Code with regard to their obligations as husband and wife as well as Articles 220 221, and 225 of the same Code with regard to their respective obligation as parents of their child. 12. Due to serious differences in discipline, character, attitude and personality, petitioner and respondent have not principally gotten along well due to disagreements in seemingly inane issues further aggravated by their emotional immaturity and irresponsibility which became manifest only after their marriage; 13. Petitioner and respondent do not possess the mind, the will and the heart to assume their essential marital obligations have shown indifference and hostility to conjugal life from the beginning of marriage; 14. The perceived domineering personality of petitioner and the philandering ways of respondent have rendered them both incapable of compying with their mutual obligations of love, respect and fidelity towards each other. Thus, both parties have shown their failure to render mutual help and support to each one; 15.

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