Republic of the Philippines

REGIONAL TRIAL COURT

FIRST JUDICIAL REGION
BRANCH 6
La Trinidad, Benguet

ELENA H. DELO,
Plaintiff, CIVIL CASE No. 1458
FOR: PETITION FOR
SEPARATE
-versus- SUPPORT

LEON C. DELO,
Accused.
x-------------------------x
PETITION
Plaintiff by the undersigned counsel, and unto this Honorable Court, states:

1. That the Plaintiff Elena H. Delo and herein defendant Leon C. Delo, are wife and
husband, respectively, having been married May 10, 2000 at the Baguio
Cathedral, Baguio City;

2. That out of this wedlock, two (2) children were born, namely, Leandro Delo and
Helen Delo;

3. That up to December of 2009, the marital relations between the plaintiff and the
defendant were harmonious, until January 2010 when the defendant refused or
failed to heed her request to have separate dwelling where they could live
together as a family;

4. That since February 2010 up to the filing of the petition, defendant who already
had taken a concubine, had not given any support to her and their two children;

5. That in answer to petitioner’s extra-judicial demands for monthly support made

on 28 February 2010, the defendant only offered Two Thousand Pesos
(Php2,000.00);

6. That in view of this infidelity on the part of the defendant, the plaintiff was
compelled to live separately, together with her minor children;

7. That the defendant earns a fixed monthly income of Twenty–Four Thousand

Pesos (Php24,000.00), while the plaintiff, being a plain housewife taking care of
her two minor children, have nothing, and at present live on the charity of
friends;

8. That in view of the necessities of the plaintiff and her minor children, the sum of
Twelve Thousand Pesos (Php12,000.00) would be reasonable amount for the
support of the plaintiff and her minor children;

9. That without fault on her part was compelled to file action for separate support,
thereby having incurred expenses by way of Attorney’s fees.
 PRAYER

WHEREFORE, premises and law considered, it is respectfully prayed that the

defendant be ordered to pay the plaintiff by way of regular support and maintenance, the
sum of Twelve Thousand Pesos (Php12,000.00), payable on or before the fifth day of each
month; and that the plaintiff recover of the defendant the sum of Fifteen Thousand Pesos
(Php15,000.00) for the Attorney’s Fees, and the cost of this suit.

And for such other reliefs as may be just and equitable in the premises.

Baguio City for La Trinidad, Benguet, Philippines, this 10th day of June, 2011.

ATTY. FRANCIS ALLEN T. PALIGAN Jr.

Counsel
Rm. 506 National Life Building,
Session Road, Baguio City
Roll No. 44354: 5/15/06
PTR No. 8703380, 2-05-11, Baguio City
IBP Lifetime No. 70445, Baguio-Benguet

REPUBLIC OF THE PHILIPPINES }

DONE: IN THE CITY OF BAGUIO } S.S.
X ========================== X
 VERIFICATION AND CERTIFICATION
AGAINST FORUM SHOPPING

I, ELENA H. DELO, of legal age, Filipino citizen, with postal address at Number JC-
153 Pico, La Trinidad, Benguet after having been duly sworn to in accordance with law do
hereby depose and state that:

1. I caused the preparation of this petition; that the contents thereof were duly
explained to me; that I fully understood all its contents and that the same and all the factual
matters stated therein are true and correct of my own knowledge.

2. I have not commenced any action or proceeding involving the same issue in any
Court or before any other agency or tribunal and that to the best of my knowledge, no such
action or proceeding is pending before any Court, any agency or tribunal; and if there be
any; that I undertake to inform this Honorable Court within five (5) days.

IN WITNESS WHEREOF I have hereunto set my hand this 10 th day of June 2011 in
the City of Baguio, Philippines.

ELENA H. DELO
Affiant

SUBSCRIBED AND SWORN to before me in the City of Baguio this 10 th day of June
2011 by Elena H. Delo, personally known to me, who is the same person who personally
signed before me the foregoing affidavit and acknowledged that she executed the same.

LIYA ORTEGA-RODRIGUEZ
Notary Public
Until December 31, 2012
Doc. No. __ 91_; PTR No. 050183/Baguio City/01-11-11
Page No. __19_; Roll of Atty. No. 8121983
Book No. I ; IBP Lifetime Membership No. 9031984
Series of 2011. Baguio-Benguet