Republic of the Philippines

REGIONAL TRIAL COURT

National Capital Judicial Region
Makati City, Branch ______

LEONILO ANTONIO,
Petitioner, Civil Case No._______
For: Declaration of Nullity of
- versus - Marriage

MARIE IVONNE F. REYES,

Respondent.
x--------------------------------x

PETITION

COMES NOW petitioner, by the undersigned counsel and unto this

Honorable Court, most respectfully alleges:

1. Petitioner, LEONILO ANTONIO, is a Filipino, of legal age, with

residence at _________ Makati City, while respondent is
likewise a Filipino, of legal age, with residence at _______
Makati City, where she may be served with summons and
other legal processes;

2. Petitioner and respondent are husband and wife, having been

legally married on December 6, 1990, at the Sta. Rosa de Lima
Parish, Bagong Ilog, Pasig, Metro Manila, a copy of their
marriage certificate is hereto attached as Annex “A”;

3. No properties were acquired by the parties during their

marriage nor were any debts incurred by the parties;
4. The parties met each other in a function in August 1989 and
continued to see each other exclusively for one (1) year before
they mutually decided to get married;

5. During their marriage, respondent persistently, unabashedly,

and continuously told petitioner lies involving her personal
status specifically as to her educational attainment,
misrepresenting herself to have graduated with a degree in
psychology, when in truth and in fact, she was a BS Finance
graduate from the University of Santo Tomas, a copy of her
transcript of records (ToR) is herein attached as Annex “B”;

6. She also lied about her employment, claiming that she was a
singer under Blackgold label, a music company, when she is
not as evidenced by the roster of artists of Blackgold label
herein attached as Annex “C”;

7. Respondent’s unbridled lying even went as far as to invent

non-existent persons named Babes Santos and Via Marquez
which she identified as her friends who allegedly sent her
letters touting her as the money-maker of Blackgold label, a
copy of said letters are herein attached as Annex “D”;

8. Not only was respondent’s lies limited to those above-

mentioned, she even proudly told petitioner that a luncheon
show was held in her honor at Philippine Village Hotel on
December 8, 1979, which was discovered by petitioner to be a
complete lie, as evidenced by the certification by the Director
of Sales of said hotel that no such occasion had taken place,
which is herein attached as Annex “E”;

9. Respondent also exhibited extreme bouts of insecurity and

jealousy over petitioner to the extent of calling up his
officemates to monitor his whereabouts;

10.Respondent’s excessive lying resulted to the denial of

petitioner’s right under Article 68 of the Family Code to mutual
 respect and destroyed petitioner’s trust to her which
effectively undermined the foundation of their marital bond;

11.Petitioner engaged the services of Dr. Jay Lopez, a clinical

psychologist, who observed that respondent’s lying and
extreme jealousy is pathological and concluded that based on
his findings, respondent was psychologically incapacitated as
sanctioned by Article 36 of the Family Code to perform her
essential marital obligations;

12.That said psychological defect or illness of respondent is grave,

serious and incurable and existed prior to the marriage and
became manifest during its existence.

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed that the

marriage of the petitioner with the respondent be declared a nullity. It is likewise
prayed that if and when parties are able to enter into an extrajudicial settlement
as to custody and joint parenting, the same be adopted by this Court and in the
absence thereof, a fair and just settlement of their rights and obligations as
parents be adjudicated by this Honorable Court. We pray for such other reliefs,
just and equitable under the premises.

March 8, 1993. Makati City.