Republic of the Philippines

REGIONAL TRIAL COURT

National Capital Judicial Region
Branch 22, Manila

KRISSY BELFORT,
Petitioner,


-versus- CIVIL CASE NO. 4321
For: Declaration of Nullity of Marriage


JAMES TAN,
Respondent.
X------------------------X

PETITION

PETITIONER, by counsel and unto this Honorable Court most
respectfully states that:

1. Petitioner, a Filipino, of legal age and with residence at 20 Pilar
St., Pandacan, Manila.

2. On the other hand, Respondent, a Filipino, of legal age and a
resident of 10 Lardizabal St., Sampaloc, Manila, where he may
be served with summons and other processes of this Honorable
Court.

3. The Petitioner and Respondent are husband and wife, having
been married on civil rights in Virac, Catanduanes. A copy of
their Marriage Certificate is hereto attached as Annex A.

4. They became acquainted after a mutual friend introduced them
to each other. Eventually, they became sweethearts.


5. Consequently, on October 10, 2004, they got married.

6. After this, Petitioner noticed major changes in Respondents
attitude and behavior. He likes to hang-out with lots of friends
every night that will last until the wee hours in the morning. He
began abusing Petitioner verbally and emotionally. He dislikes
being confronted by her and always gets mad even an innocent
question asked by the Petitioner.

7. Respondent further neglects his marital roles by not spending
time with his wife. He is always out of the house even on
weekends and during his day offs. He does not show any more
concern to his wife.

8. In one instance when they fought, the altercation turned
physical when Respondent slapped Petitioner on her face.

9. In several instances, Petitioner caught Respondent having
women text mates which became an added reason for their
frequent arguments and quarrels.

10. To give Respondent a space to ponder upon their
relationship, Petitioner decided to move out of her in-laws
house.

11. Respondent instead of finding ways to reconcile with the
Petitioner even continued with his activities and seemed to
enjoy it than being with his wife.

12. As found out by clinical Psychologist, Respondents
behavioral patterns were affected during his early
developmental years where he was raised and exposed in an
unfavorable environment. He came from a dysfunctional family
where both of his parents had previous unsuccessful marriage
leading to their respective extramarital affairs.

13. Respondent was found to be suffering from psychological
incapacity which incapacitated him to perform his essential
marital obligations which is deemed serious, incurable and
existing even prior to his marriage. Such personality deficit is
classified as NARCISSISTIC PERSONALITY DISORDER
WITH ANTISOCIAL TRAITS as found in Psychological
Evaluation Report by Clinical Psychologist Deniece Chua
hereto attached as Annex D.

14. Petitioner would like to start her life anew and now seek
to this Honorable courts intervention to declare her marriage
with Respondent a nullity.

PRAYER

WHEREFORE, premises considered it is most respectfully prayed of
this Honorable Court that the marriage of the Petitioner with the
Respondent to be declared an absolute nullity and that accordingly by
the court to issue an order to the local Civil Registry of Virac,
Catanduanes, and to all government agencies concerned of the
absolute nullity of marriage and make corresponding and appropriate
annotation in their records.
Other reliefs just and equitable under the premises are likewise
prayed for.

City of Manila, October 24, 2014.



FRANCO-GARDIOLA LAW OFFICE
Counsel for Petioner
145 Herera Tower
Pedro Gil, Manila

By:

Atty. Gretchen G. Dolatre
Counsel for Petitioner
Roll No. 3241 March 16, 2014
PTR No. 6121 March 16, 2014
IBP No. 2643 March 16, 2014
640-D MontanaStreet,Sampaloc, Manila
Tel. No. (02) 415-1156
gretah1687@yahoo.com
MCLE Compliance No. I


VERIFICATION AND CERTIFICATION OF NON-FORUM
SHOPPING

I, KRISSY BELFORT, of legal age after having duly sworn in
accordance with law, states that:

1. I am the petitioner in the above stated case.

2. I caused the preparation of this petition.

3. I have read the contents thereof and the facts stated therein are
true and correct of my personal knowledge and based on authentic
records.

4. I have not commenced any other action or proceeding involving the
same issues in any court, tribunal or quasi-judicial agency and to the
best of my knowledge, no such other action is pending therein.

5. If I should learn thereafter that a similar action or proceeding has
been filed or is pending before any court, tribunal or agency, I
undertake to report that fact within five days therefrom, to this
Honorable Court.


Krissy Belfort
Affiant


SUBSCRIBED AND SWORN to before me this 24th day of
October 2014 at Manila, affiant exhibiting to me her SSS I.D. No.
4361 issued on March 26, 2013 at Makati.


Marjorie Diomampo
Notary Public, Manila
Roll No. 231 August 16, 2014
IBP No. 412 August 16, 2014
PTR No. 120 August 16, 2014
Unit 628 Crown Tower,
Pedro Gil St., Manila
Commission Serial No. 1003
Until December 31, 2016


Doc. No. 341
Page No. 152
Book No. IV
Series of 2014










Copy furnished:

ATTY. MA. FLORENZ NIOG
Counsel for respondent Place: _____________
2486, Legarda Street, Date: ______________
Sampaloc, Manila Receipt No.: _______

OFFICE OF THE SOLICITOR GENERAL
OF THE PHILIPPINES Date: ______________
OSG Building, 134 Amorsolo St., Place: _____________
Legazpi Village, Makati City Receipt No.: ________

OFFICE OF THE CITY PROSECUTOR
FOR THE CITY OF MANILA Date: ______________
Room 208, Manila City Hall, Place: _____________
Manila Receipt No.: ________

THE BRANCH CLERK OF COURT
Regional Trial Court Date: ______________
Branch 22, Place: _____________
Manila Receipt No.: _______


EXPLANATION: The foregoing petition was served to the adverse
parties through registered mail due to lack of messengerial personnel
to serve the same.

GRETCHEN G. DOLATRE