Beruflich Dokumente
Kultur Dokumente
PETITION
Now COMETH, petitioner, through the undersigned counsel and to
this Honorable Court, respectfully alleges:
1. That petitioner Gina Lao Choi is of legal age, married, Filipino and
resident of 1473 Banawe St., Quezon City;
9. That after the day of their wedding they resided at the residence
of respondent’s mother.
10. That they slept together on the same bed and on the same room
however, they have never had any moment of intimacy and sexual
intercourse as Complainant always heads straight to bed.
11. That the same thing happened on the second, third and fourth
nights of staying in the residence of respondent’s mother.
13. That they stayed for four days in Baguio however in the said
stay, no sexual act or any form of intimacy occurred between husband and
wife.
14. That from May 22, 1988 to March 15, 1989, no sexual act
occurred between Plaintiff and Respondent nor did Plaintiff see
respondent’s penis.
18. That plaintiff sought the second opinion of a doctor, Dr. Flanillo
Javier, as to her husband’s condition.
21. That plaintiff came up with such conclusion because despite all
efforts, respondent does not want to have sexual intercourse with her. That
such has tantamount to a refusal to perform an essential marital
obligation which is the creation of the family.
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13. That finally, the petitioner has therefore no other recourse but to
seek judicial relief. The prospects or possibility of respondent to reform
and assume his essential marital obligation is a remote possibility, if not
a hopeless expectancy.
PRAYER
Petitioner prays for such other relief she may be entitled to in the
premises.
By:
______________
Atty. Joel Mendoza
Commission Serial No. 4569
Until December 30, 1991
Roll of Attorney 14555
IBP. No.1111/January 1, 1987/Manila
P.T.R. No. 2223/January 1, 1988
Roll No. 2256
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VERIFICATION-CERTIFICATION
ON NON-FORUM SHOPPING
3. That all the allegations therein are true and correct of my own
knowledge and based on authentic records;
_____________
Gina Lao Choi
Affiant