Beruflich Dokumente
Kultur Dokumente
LOISA P. MANSALANG,
Petitioner,
PETITION
COMES NOW petitioner, through the undersigned counsel and to this Honorable
Court, respectfully alleges:
3. That petitioner and respondent celebrated their marriage on February 14, 2009
before the Parish Church of San Agustin, Dumaguete, certified true copy of their
Marriage Certificate is attached and made integral part hereof as Annex “A”;
4. One (1) legitimate child was born out of their union namely: MAYORA P.
MANSALANG, born on November 17, 2009. (A copy of her Certificate of Live birth is
attached hereto and made an integral part hereof as Annex “B”.)
5. They have no written agreement executed before the marriage to govern their
property relations nor have any community property acquired during their marriage. They
have no debts;
7. That in a short span of time they had been together, this is the time which the
petitioner describes as a period where the respondent’s instability, psychological or
otherwise, showed up;
8. That other instances, wherein such instability could be reasonably inferred are
as follows:
a. After their marriage, the respondent gave up his job at Bolongaita Law
firm as Assistant Manager without justifiable reason;
d. He is a womanizer;
f. That the respondent does not want to have a child with the petitioner
because according to him it will just cause burden for him;
g. That parties would fight even for the smallest things through not due to the
fault of the petitioner, and frequently, the respondent would always apologize to the
petitioner, but later on, he will repeat his quarrelsome and troublesome ways;
h. He prefers to hang out with friends and with her flings instead of being with
petitioner;
a. That there were many times when the respondent never even kissed the
petitioner. Respondent would not even look at her whenever they spoke with each other.
She was always the one, who holds or hugs him so that they may become closer to each
other but every time she tries to be closer to him, he simply had to always turn his back to
her. This is causing so much unbearable emotional and psychological pain on the part of
the petitioner;
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b. That petitioner told the respondent that they should discuss what went
wrong between them and hopefully they could work it out again. The petitioner
verbalized all of the things she had noticed and felt, knowing that everything works out
when there is an open communication. She told him about the lack of passion, respect
and romance in their relationship. The respondent just ignored her pleas;
d. That respondent did not stop gambling and using alcohol and drugs;
10. That the petitioner already gave up on the respondent after trying to give all her
efforts just to save her marriage to a man who, as shown in the foregoing, is not cognitive
to and psychologically incapable of performing, his basic marital covenants to herein
petitioner;
11. That further, respondent’s psychological incapacity from all indications appears to
have been manifesting at the time of the celebration of marriage. Although said
manifestations were not then perceived, the root cause shall be proved to such an extent
that respondent could not have known the obligations he was to fulfill or knowing them
could not have validly performed them. It is of such incapacity that respondent was
unable to assume his marital obligations;
12. That the respondent’s incapacity to fulfill his essential marital obligations appear
to be grave, incurable and deeply ingrained, thus; warranting the issuance of the Decree
of Nullity of petitioner’s marriage with the respondent;
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 obligations is a remote possibility, if not a hopeless expectancy.
PRAYER
1. Declaring the marriage entered into by the parties as NULL and VOID on
the ground of psychological incapacity of the respondent;
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2. Confirming permanent custody of the minor child, MAYORA P.
MANSALANG in petitioner.
3. Holding that petitioner shall henceforth revert to and use her maiden name
LOISA C. PANINI.
Petitioner prays for such other relief she may be entitled to in the premises.
VERIFICATION-CERTIFICATION
ON NON-FORUM SHOPPING
I, Loisa P. Mansalang, of legal age, Filipino citizen, resident of San Jose, Banilad,
Dumaguete City, Philippines, after having been sworn to in accordance with law, depose
and say:
3. That all the allegations therein are true and correct of my own knowledge and
based on authentic records;
4. That I hereby certify under oath that I have not heretofore commenced any
other action or proceeding involving the same issues in the Supreme Court, Court of
Appeals or any other tribunal or agency, and that to the best of my knowledge, there is no
other action or proceeding, which is pending before this Honorable Court, Court of
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Appeals, Supreme Court or any other tribunal or agency involving the same parties and
the same issues, and that if I learn hereafter that there are other proceedings pending
before this Honorable Court, or any other tribunal or agency, I hereby undertake to report
that fact within five (5) days therefrom to this Honorable Court.
_____________
Loisa P. Mansalang
Affiant