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REPUBLIC OF THE PHILIPPINES

__ JUDICIAL REGION
REGIONAL TRIAL COURT
BRANCH ___
Manila

IN THE MATTER OF
ANNULMENT OF MARRIAGE
BETWEEN ENRICHMENT
GINSALO – GANZANO and
XIANIN GANZANO

CIVIL CASE NO.


______________
FOR: ANNULMENT OF
MARRIAGE

ENRICHMENT GINSALO -
GANZANO
Petitioner,

-versus

XIANIN GANZANO
Respondent.

X---------------------------------X

PETITION

Petitioner ENRICHMENT GINSALO - GANZANO, by counsel, and unto this


Honorable Court, most respectfully submits this Petition for Annulment of Marriage
and avers, THAT:

1. Petitioner is of legal age, married, Filipino, and residing at ____________, Manila


City, where he may be served with legal and judicial processes of this Honorable
Court;
2. Respondent ___________, is likewise of legal age, Filipino, and with postal address
at ________, where she may be served with summons and other legal or judicial
processes;

FACTS

3. Petitioner has ________________


4. __________________________________________________

5. Their relationship was steady and smoothly sailing until ____________

6. They had a wedding on May 1, 2015. A copy of the Marriage Certificate is hereto
attached as ANNEX “A”;

CAUSE OF ACTION
(Nullity of Marriage on the Ground of Psychological
Incapacity)

7. Respondent was not ready for a married life. He was not over with his former love,
even going to the extent of making excuses and lies just to see… The New Civil
Code provides that:

“Article 68: The husband and wife are obliged to


live together, observe mutual love, respect and
render mutual help and support”

8. Consequently, it created emotional, psychological and social problems to their


family life, which resulted in psychological disturbances. The respondent could not
perform her essential marital and parental obligations with the family from the
beginning, to wit:

“Article 36: Marriage contracted by any party


who, at the time of the celebration, was
psychologically incapacitated to comply with
the essential marital obligations of marriage,
shall likewise be void even if such incapacity
becomes manifest only after its
solemnization.”

9. Petitioner attempted to save the marriage but failed…


PRAYER

WHEREFORE, premises considered, it is respectfully prayed that after due


hearing, the marriage between the petitioner and respondent described in the foregoing
be declared NULL AND VOID AB INITIO on the ground of psychological incapacity under
Article 36 of the New Family Code. It is further prayed that the Court issue the following
Orders:
1 To declare the civil status of the Petitioner as single;
2 To effect the cancellation of the Marriage Contract with registry number ________
between the petitioner and respondent as recorded in the Civil Registry of
________, the National Statistics and Census Office and other related government
agencies;
3 To liquidate the conjugal property in favor of the innocent petitioner spouse
pursuant to Article 147 of the New Civil Code;

Petitioner prays for such other reliefs as are just and equitable under the premises.

Done this ___ day of ________________ 2017.

AQUINO LAW OFFICE


RM 203 MARIPOLA BLDG., 109 PEREA ST., LEGASPI VILLAGE, MAKATI
CITY

BY:

ATTY. MARK DAVID I. AQUINO


Roll No. 64163
IBP No. 1007355 - Batangas
PTR No. 600314 – MANILA, 05 JAN 2017
MCLE Compliance No. V-22258 – 15 JUNE 2016
Contact No. 09-xxxxxxx

ATTY. AYCE ANN SADIWA


Roll No. 68876
IBP No. 016546 – Marinduque (Lifetime Member)
PTR No. 6281934 – Makati, 30 JUNE 2017
MCLE Compliance No. EXEMPT
Contact No. 090-xxxxxxxxx
VEREIFICATION AND CERTIFICATION AGAINST FORUM
SHOPPING

I, ENRICHMENT GINSALO - GANZANO, is of legal age, married, Filipino, and


residing at ________________________________, after having been duly sworn in
accordance with law, do hereby freely and voluntarily depose and state that:

I am the petitioner in the above-entitled case;

I personally caused the preparation of the foregoing complaint and all the
statements contained therein are true and are of my own personal knowledge;

I have not commenced any case or proceeding involving the same issues in the
Supreme Court, the Court of Appeals, or any other tribunal or agency;

The to the best of my knowledge, no such action or proceeding is pending in the


Supreme Court, the Court of Appeals, or any tribunal thereof; and

That if I should learn that a similar action or proceeding has been filed or is pending
before the Supreme Court, the Court of Appeals, or any other tribunal or agency, I
undertake to report the said fact within five (5) days therefrom to the court or agency
wherein the original pleading and sworn certification contemplated herein have been
filed.

__________, ____________________, 2017.

ENRICHMENT GINSALO - GANZANO


Affiant

SUBSCRIBED AND SWORN TO before me this ___ day of __________ 2017, at


_______________, Philippines, affiant exhibited to me her Government Issued ID
_____________ No. ___________ issued on ______________ by _______________.

NOTARY PUBLIC

Doc. No. ___;


Page No. ___;
Book No. ___;
Series of 2017

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