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Republic of the Philippines

8th Judicial Region
REGIONAL TRIAL COURT
Branch 7
Tacloban City
WILSON, represented by Angela
Bofill
Complainant,

CASE NO.

-versusNICK AMOR,
Respondent
X- - - - - - - - - - - - - - - - - - - - - - -X

COMPLAINT
COMES NOW the petitioner thru the undersigned counsel, and
unto this Honorable Court, most respectfully avers:
1. The Petitioner is a minor child, represented by his mother,
ANGELA BOFILL, of legal age, Filipino, single, and a resident of
Brgy. San Joaquin, Palo, Leyte, where she can be served with
summons and notices by the Honorable court.
2. Petitioner seek for the support and the judicial or compulsory
recognition of paternity of an illegitimate child being the natural child
of the Angela Bofill and Nick Amor.
3. On the year 2000, Angela and Nick got acquainted and then
became lovers, when ANGELA was a 1 st year college student of St.
Pauls Business School of Tacloban, being the Ms. SPSBT and the
prettiest at that time, she was introduced to NICK by his friend Mark
Hammer.
4. Nick was very caring at the start of the relationship, until it led
into a romantic love affair and subsequent sexual intimacy.
5. Angela had carnal knowledge with Nick despite the fact that
she was only first year college student, but was made confident by
the promise of marriage by Nick who appeared to be matured and
responsible.

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6. On the month of September 2001, Angela got pregnant and

informed Nick about it, but was surprised by Nicks sudden change of
heart, who tried to convinced her to abort her pregnancy, even
brought her to a friend doctor to get rid of the said pregnancy, but the
doctor said that it is not possible for it is a sin and criminal offense.
7. From then on, Nick became evasive and indifferent, and
Angela was forced to leave town for Cebu to avoid scandal in the
family and discreetly hide her pregnancy, until the pregnancy was
revealed by her parents who was so furious and scolded her, but
subsequently, forgave her, and encouraged her to continue her
studies.
8. She gave birth to a baby boy on June 30, 2002, in Bethany
Hospital in Tacloban, without the assistance from Nick.
9. Angela was compelled to live with her parents in Palo with
her minor child who was baptized as WILSON, as her parents
promised to support her and her child.
10. Angela continued her studies until she finished her nursing
course and started to work in Cebu City while her growing child was
enrolled in Palo Central School under the care of her parents.
11. In view of the necessities of her growing child, whose tuition
fees are going high, the petitioner, is demanding for support from the
respondent.
WHEREFORE, premises considered, it is most respectfully
prayed unto this Honorable Court that judgment be rendered in favor
of the petitioner and that after judgment:
a. The respondent shall give his support in accordance with the
Family Code,
b. The payment of Attorneys fee upon the acceptance of this
case in the amount of Php30,000.00.
c. The payment of Attorneys appearance fee in the amount of
Php5,000.00 per appearance on the hearing of this case.
Such other reliefs and remedies under the premises are
likewise prayed for.
Tacloban City, Philippines, this 10th day of March, 2016.
Counsel for complainant

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Republic of the Philippines)

City of Tacloban
)SS.
x- - - - - - - - - - - - - - - - - - x
VERIFICATION and CERTIFICATION OF
NON-FORUM SHOPPING
I, ANGELA BOFILL, of legal age, Filipino, single, and a
resident of Brgy. San Joaquin, Palo, Leyte, after having been duly
sworn to in accordance with law, do hereby deposes and says:
1. That I am the complainant in the above-entitled
complaint and in my capacity as such, caused the
preparation of the foregoing, the contents of which are
all true and correct according to my own personal
knowledge and authentic documents;
2. That I hereby certify that I have not commenced any
action or filed any foregoing instrument involving the
same issues in any court, tribunal or quasi-judicial
agency and, to the best of my knowledge no such
other action or petition is pending therein.
IN WITNESS WHEREOF I have hereunto set my hand this 10 th
day of March, 2016, at Tacloban City, Philippines.

ANGELA BOFILL
Affiant
SUBSCRIBED AND SWORN to before me this 10th day of
March, 2016 at Tacloban City, Philippines.
Notary public
Doc. No. ----Page No. ----Book No. ----Series of 2016.

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COPY FURNISHED:
Counsel of the Respondent
Via mail

Registry Receipt

EXPLANATION
(x) Copy of this complaint was furnished to the adverse counsel via
registered mail with return card for personal service was impractical
due to lack of messengerial services.