REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

FIRST JUDICIAL REGION
BRANCH_______
Plaintiff,
COURT CASE NO.______

FAMILY

-versusfor
Defendant.
DECLARATION OF NULLITY OF MARRIAGE
x-------------------------------------------------x
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

along______________;

respondent

met

at

___________located

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.