REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
“” CITY
BRANCH _____

JOHN DOE,
Petitioner,

Versus CIVIL CASE NO.____________

For: Declaration of Nullity of
Marriage on the Ground of
Respondent’s Psychological
Incapacity under Article 36 of the
Family Code

JOHN DOE
Respondent.

x-----------------------x

PETITION

PETITIONER, by undersigned counsel to this Honorable Court,

respectfully alleges that:

1. Info of Petitioner

2. Info of Respondent

3. How petitioner met respondent

4. First impression of petitioner

5. Dating History of petitioner and respondent up until Wedding

 6. Birth of Child

7. Post Birth History of petitioner and respondent

8. Current State of petitioner and respondent

9. Discussion on Respondent’s Psychological Disorder

10. Due to respondent’s Antisocial Personality Disorder, he failed to

assume and comply with the following spousal obligations:

a)

11. Respondent, because of his personality disorder has failed to carry

out the following parental obligations.

a)

12. The marital as well as parental obligations which respondent fails

to comply with, which are manifestations of his psychological
incapacity, are the marital obligations embraced by Articles 68, 69
and 71 and parental obligations as embraced in Articles 220 and 224
of the Family Code of the Philippines.

13. Do the parties have any conjugal properties to divide amongst

them?

14. The marriage between the parties should be declared null and
void from the beginning as highly recommended by “”

WHEREFORE, petitioner most respectfully prays of this Honorable

Court to render judgment:

1. Declaring null and void ab initio the marriage of the Parties, on the
ground that: the respondent is psychologically incapacitated to
comply with the essential obligations of marriage, said incapacity
having started before marriage, but manifested during covertures,
 and the psychological incapacity is permanent, very grave and
incurable;

Other reliefs just and equitable under the premises are likewise
prayed for.

Pasig City for Imus Cavite.

June 28, 2016.

VALDERAMA LAW OFFICE
Unit G, 10th Floor Strata 100
Condominium Building
100 F. Ortigas, Jr. Road,
Ortigas Center, Pasig City
Metro Manila
Tel/Fax No. 4511594
Email: attyvalderama@gmail.com

By:

MARLON P. VALDERAMA
Roll of Attorneys No. 47546
IBP No.1025311-1/13/16-Quezon
PTR No.1431000-1/13/16-Pasig City
MCLE Compliance No. V-0017416
Issued on April 8, 2016

COPY FURNISHED:

OFFICE OF THE SOLICITOR GENERAL

No. 134 Amorsolo Street
Legaspi Village, Makati City

OFFICE OF THE CITY PROSECUTOR

Imus, Cavite