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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT


NATIONAL CAPITAL JUDICIAL REGION
FAMILY COURT
BRANCH 123, MANILA

ANGELINA JOLIE,
Petitioner,
CIVIL CASE No. 8765
-versus- For: Declaration of Nullity of
Marriage
BRAD PITT,
Respondent.
x--------------------------------------x

PETITION

COMES NOW, the petitioner through the undersigned counsel and


unto this Honorable Court, most respectfully alleges, that:

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


Filipino and a resident of Apartment 10, South Cembo, Guadalupe, Manila
City 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 Block 8 Lot 6, Barrio Bisaya,
Guadalupe, Manila, where he may be served with summons, notices and
other processes of the Honorable Court;
3. Petitioner and respondent met and were introduced with each
other in Arellano University during their college days where they were
schooled and within a short span of time of having known each other,
soon thereafter, a whirlwind courtship and romance transpired and
eventually ended up to a marriage of the two;

4. Barely after a date or two, petitioner got herself impregnated


and persuaded respondent that he goes with her;

5. On 24 July 2008, a few months after a whirlwind courtship


and romance, respondent by means of false pretenses initiated and
convince petitioner to enter into a marriage at the Manila Cathedral,
Manila, a copy of the Certificate of Marriage is hereto attached as Annex
A forming an integral part hereof;

6. During their cohabitation as husband and wife, petitioner and


the respondent begot three children, the first child named CHELSEA
PITT was born on 23 April 2008; the second child named BEATRICE
PITT was born on 10 June 2010; the third child named WILLIAM PITT
was born on 06 March October 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;

7. After giving birth to their third child, respondent initiated again


to petitioner his desire to finish his degree in college to which the latter
conformed and permitted respondent to enroll in his former school in
Arellano University;

8. Petitioner, as responsible family woman, took the responsibility


of taking care and nursing of their children with the thought that
respondent, though away from them, was busy with his studies but on
the contrary, respondent did nothing of that sort except to live a life of
an unmarried man;

9. On March 2, 2014, petitioner, in order to best improve their


lives flew to Dubai as an overseas worker where she was employed to
work as the Head Engineer of the Burj Al-Arab Hotel with a lucrative
salary compared to what she receives in the country;

10. It was while petitioner works herself to death in her quest to


seek for greener pasture that she had received information from her
friends about respondents promiscuous way of living when he took a
concubine and began having an illicit affair with her in Arellano
University;

11. Petitioner, in her desire to know the truth, asked her father to
check on this information only to be informed that respondents illicit
relationship with a certain Paula Avelino resulted to a child in the name
of Julio Montez, born on October 2015, and as can be gleaned from the
data, the former is registered as the father, a copy of the birth certificate
is hereto attached as Annex E forming an integral part hereof;

12. Petitioner, during her vacation from Dubai, confronted


respondent at his parents house about his infidelity, however, the latter
opted to say nothing that made the former doubt that indeed there was
truth to what was relayed to her by her friends;

13. With respondents prolong stay with his parents, it became a


common knowledge among their neighbors that respondent came from
the Taft areas with another woman and very much pregnant and lived
together as husband and wife;
14. Due to humiliation prompted petitioner to file the necessary
criminal complaint against the respondent and his concubine, worst,
even after said case was filed, respondent again had a second child to
the same to woman but this time, the babys father was registered as
unknown a copy of the birth certificate is hereto attached as Annex F
forming an integral part hereof;

15. A court decision has been rendered convicting the respondent


and his concubine of the crime of Concubinage, a copy of the decision is
hereto attached as Annex G forming an integral part hereof;

16. Worst is that respondent did not in any manner bother to give
their familys welfare a thought when he took a concubine which only
depicts that respondent was never ready for a married life, thus,
neglecting to perform his marital duties and obligations to the petitioner;

17. Respondent at the time of the celebration of their marriage


knew for a fact that he was psychological incapacitated to comply with
the essential marital obligations of marriage although during their
courtship period, he hid these facts to the petitioner and only became
apparent after the solemnization and celebration of the said marriage;

18. The respondents psychological incapacity is traceable to his


irresponsibleness, immaturity, and infidelity, just like the way he had
abandoned petitioner and have an illicit affair with another woman that
out of the sexual intercourse with her produced two (2) children outside
marriage, and if respondent would just tolerate the past antecedents and
remain married with the petitioner, surely the former would neglect his
duties to give physical, moral and spiritual support as husband and would
only labor an affliction that makes a common life as husband and wife
impossible and unbearable;
19. Respondents act affirms his adamant willful refusal to take the
marital obligations of establishing a happy family. His act is indicative of
a hopeless situation and a serious personality disorder which are
permanent and incurable combined with his infidel ways 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;

20. Petitioner and respondent have acquired a mansion in


Forbes Park, five cars, Php 25 Million in the bank and an Italian
Restaurant in Makati City while their marriage subsist;

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


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

22. Before the filing of this petition, petitioner had exerted earnest
efforts for possible reconciliation with respondent but the same went all
for naught;

23. The dissolution of their marriage will serve the best interest,
peace and tranquility of the plaintiff and the defendant.

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 as NULL AND VOID AB INITIO the marriage


between petitioner ANGELINA JOLIE and BRAD PITT 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.

22nd day of August 2017. City of Manila.

(SGD.) QING KHONG


Counsel for the Petitioner
IBP No. 582111 12-22-04
PTR No. 1234567 12-22-04
ROLL No. 12345 5-8-91
Manila City
VERIFICATION AND CERTIFICATION

I, ANGELINA JOLIE, of legal age, married and a resident of


Apartment 10, South Cembo, Guadalupe, Manila City, after having been
duly sworn to in accordance with law do hereby depose and state that:

1. That I am the plaintiff in the above entitled case;

2. That I have caused the preparation of this complaint;

3. That I have read its allegations and the same are true and
correct to the best of my own personal knowledge;

4. That I further certify that, and to best of my knowledge there


is no other petition involving the same issues raised herein has ever been
filled with the Supreme Court, Court of Appeals, any of their divisions, or
any tribunal or agency;

5. That I undertake to notify this Honorable Court, five (5) days


from the notice of any such pending action or proceeding.

(SGD.) ANGELINA JOLIE


Affiant

SUBSCRIBED AND SWORN to before me this 22 August 2017 in


the Manila City. The affiant exhibiting to me his SSS No. N26-01-
004190 issued by Social Security System on May 01, 2001.

(SGD.) QING KHONG


Notary Public
Doc No. 1234 Until Dec. 31, 2020
Page No. 123 PTR No. 1234567 12-22-04
Book No. 1 ROLL No. 12345 5-8-91
Series of 2017 IBP NO. 6574387695
MCLE NO. 7746-75835
Manila City