PETITIONER: IN THE DISTRICT COURT

Rubi M. Serano Regional Trial Court

National Capital Judicial JUDICIAL DISTRICT
Region, Branch 13,
Manila

DEFENDANT:

Marko C. Lu Republic of the {COUNTY, STATE}

Philippines

PETITION FOR MODIFICATION FOR ILLEGITIMATE CHILD SUPPORT

1.) Petitioner, Rubi M. Serano, is of legal age and a Filipino citizen, who lives at R. Magsaysay, Sta.
Mesa, Manila, filed a petition the court to the Order of Support in accordance with Article 176 of the
Family Code of the Philippines for her daughter named Marga S. Lu who she conceived out of wedlock
with his college friend, Marko C. Lu who is now legally married with Roselle B. Lu. They have twins
namely Bernard Lu and Bernabe Lu. Rubi's occupation is a BPO or a call center agent in Alorica Manila.
She's a single mother and not married yet to anyone and also doesn't have other child aside from Marga.

2.) Defendant Marko C. Lu is also of legal age and a Filipino citizen who lives in Palm High, Makati City.
For the last 8 years, he has been in contact with Rubi M. Serano and Marga S. Lu and has been
supporting the latter. He even agreed for the usage of his surname "Lu" by her daughter. With his legal
wife, Roselle B. Lu having knowledge about his illegitimate child except for her own family. They have
hidden the truth from them and other people in fear of disbarment from his profession as a lawyer. His
occupation is a lawyer in Makati Firm.

3. Now that Marga S. Lu has turned 15 years old, the defendant has gone unreachable and can't be
contact. He stop asking for the well-being of her daughter whether through phone or by personal
meetings. He stop visiting nor giving her allowance. Or he gives but every other month, not a reliable
pattern of every month allowance.

4.) The last time, November 16, 2015, Marga had a dengue fever and almost died due to lost of blood and
not for getting admitted immediately in hospital because her father, Marko was nowhere to be found. Rubi
just got fired from her work as a call center so she had no other means of money. Thankfully, a co-worker
of hers lent her money for the medical bills. The negligence and uncaringness of Marko almost cost the
life of Marga.

5.) Marga S. Lu is currently a 1st Year Senior High student studying in Far Eastern University (FEU) and
almost considers of stopping from attending school because no one is financially supporting her. Her
mother Rubi's income is sufficient only for their apartment and food. Rubi has been estranged from her
own relatives. They can't ask for favor from them wherefore they ask for the court to grant the
Modification for Illegitimate Child Support (Support for Marga S. Lu).

The current Order of Support stipulates the following conditions:

1.) Annual or monthly support atleast 1/2 of the legitimate children's support, Bernard Lu and Bernabe Lu
2.) Send support if asked in school- related finances
3.) Send support for medical and health finances

I move the court to modify the Order of Support in the following ways:
1.) Instead of monthly, weekly allowance or support for atleast 1/2 of the legitimate children's support,
Bernard Lu and Bernabe Lu
2.) Send support not only for school-related finances but also for self-development and leisure.
3.) Send support for medical, food, and shelter.
I request these modifications for the following reasons:
1.) Having difficulty to reach out to the father of my daughter because he isn't responsive anymore.
2.) I'm having financial crisis so I can't fully support for my child's expenses like school, food, and house
expenses.
3.) She's still undeage or not yet 18 years old and above to provide financially for herself.
Attached is a completed Domestic Relations Affidavit, a Child Support Worksheet, last year ’s income tax
return and my most recent pay stub.

PETITIONER SIGNATURE

Subscribed and sworn to before me this 9th day of October 20 19

(Notary Public),

County.

My commission expires 9th day of October 20 29

PRAYER

WHEREFORE, in the interest of substantial justice and taking into

consideration the foregoing facts, it is most respectfully prayed of this Honorable
Court that the petition for the modification, in conformity with Article 176 of the
Family Code, of the Decision dated October 9, 2019 rendered by Branch 13 of the
Regional Trial Court of Manila and, pursuant thereto, Marko C. Lu's ’ immediate
support for his child and for his answer for the petition.
Other forms of relief and remedies, which the Honorable Court may deem
just and equitable under the premises, are likewise prayed for.
Manila, Philippines, October 9, 2019.

Atty. KASSANDRA MAE PINEDA

Counsel for the Petitioner
Public Attorney’s Office
Hall of Justice, Ramon Magsaysay St.,
Manila

ROLL NO. _____, 01/01/2019

IBP NO. ______, 01/01/2019, Davao City
PTR No. _______, 01/01/2019, Davao City

VERIFICATION/CERTIFICATION OF NON-
FORUM SHOPPING

I, RUBI M. SERANO, Filipino, of legal age with address at R. Magsaysay Blvd, Sta. Mesa,
Manila, after having been duly sworn on accordance with law depose and say:
That I am the plaintiff in the above-entitled case;
That I caused the preparation of the foregoing Petition and I have read the allegations therein and certify
that the same are true and correct of my own personal knowledge;

That I further certify that I have not commenced any other action involving the same issues before the
Supreme Court, Court of Appeals or any division thereof or any tribunal or agency; and to the best of my
knowledge no such action is pending before the Supreme Court, Court of Appeals or any division thereof
or any tribunal or agency;

That in the event that any action involving the same should be made known, I hereby bind myself to
report the same within five (5) days from knowledge thereof to this Honorable Court.

WITNESS WHEREOF, I hereunto set my hand this 9th day of October, at Sta. Mesa, Manila,
Philippines.

RUBI M. SERANO

Plaintiff

SUBSCRIBED AND SWORN TO before me this 9 October 2019 at Sta. Mess, Maniala affiant
having exhibited to me his B.I.R. Tax Identification No. 009-123-456-000 issued on 3 March 2000 at
Quezon City, Philippines.

NOTARY PUBLIC

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