REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
CEBU CITY BRANCH 143

Ms. TMG Petitioner,

CIVIL CASE NO. 143

versus FOR: Declaration of Nullity
of Marriage

Mr. MPG
Respondent.
x-------------------------------------------------------x

PETITION

PETITIONER, by counsel and to this Honorable Court most

respectfully state:

I. PARTIES

Petitioner, MS. TMG, is of legal age, married to the respondent

but separated in fact, and a resident of No. 123, Apas, Cebu City.
She may be served with summons and other court processes through
her counsel’s office address at Justice League Law Offices, 33 rd Floor,
Cebu IT Park, Apas, Cebu City.

Respondent, MS. MPG, of legal age married to the Petitioner

but separated in fact, and a resident of No. 187 Cambridge Street,
Lahug, Cebu City, where he may be served with summons and other
court processes;

II. FACTS BEFORE THE MARRIAGE

2.1 Petitioner was born on November 24, 1985 to a conservative
family who are members of the Opus Dei;
2.2 Petitioner is currently employed as a Hotel Banquet Manager in
a 5 star hotel in Cebu;
2.3 Petitioner has always been sheltered and quite naive;
2.4 Respondent on the other hand was born on April 17, 1984 to a
pure Chinese family;
2.5 Respondent took up his pre-med and medicine proper in UST;
2.6 During Respondent’s pre-med and medicine proper in UST, he
had undergone annual psychological evaluation with the
Guidance Counselor. A copy of the psychological evaluation
from the Guidance Counselor is hereby attached as “Annex A”;
2.7 During Respondent’s younger years he is used to attention
because of his appearance. He has always been close to girls
because of his good looks and said to be a ladies’ man. He has
many girlfriends from the past and up to present;
2.8 The parties met each other in Ponticello Bar in Makati sometime
in the year 2010 through common friends;
2.9 They dated secretly for almost two years after their meeting,
this is because Respondent did not want getting tied up to
anybody. More so, he did not want to get into any serious
commitment with the Petitioner;
2.10 Respondent wants grandeur things in life. He always wants the
best of everything and will not settle for anything less;
2.11 Respondent has always been self-absorbed that he always put
himself first without taking into consideration the feelings of
others. This is manifested by the fact that even if his family
never approved of Stella, he did not care. He just do what he
wants without regard to his family that is why they got married
without the approval of both their parents;
2.12 On October 10, 2010, the parties were married without the
approval of both their parents. A copy of the parties Marriage
Contract is hereby attached as Annex “B”;

III. FACTS DURING THE MARRIAGE

3.1 Because of Respondent’s grandiose style, they were given
several properties as wedding gifts, including a condo in
Legaspi Village and a parcel of land in Batangas. They have two
cars and a bank account with One Million in it;
3.2 The parties subsequently begot one child named Chloe, now 7
years old. A copy of Chloe MPG Birth Certificate is hereby
attached as Annex “C”;
3.3 They have different views on Sexual Intimacy which has caused
a strain in their relationship;
3.4 The parties’ marriage proved to be very frustrating for the
Petitioner. Respondent’s extreme lack of love and respect
towards the petitioner became more apparent; to state:
3.4.1 Respondent wants to experiment in bed despite the fact
of knowing that Ms. TMG comes from a family who are
members of the Opus Dei and are very conservative.
Thus, Petitioner was very offended with Respondent’s
experimentation. She finds it demeaning and disgusting;
 3.4.2 There were rumors of Respondent’s alleged infidelity
involving a young intern in his department in the hospital
where he is a resident of;
3.4.3 Rumors regarding Respondent’s infidelity is even more
evidenced by the fact that after having their first child,
they never had sexual relations for almost two years now;
3.4.4 They started having frequent fights for over a year now
and in the heat of one of those quarrels, Respondent
became violent and in his anger, pushed the Petitioner,
causing the latter to fall to the ground and hit her head;
3.5 Saddened by the aforementioned circumstances, Petitioner
focused more on her career where she has started to spend
more time at work and afterwards, met with her friends who
are either separated or are lesbians to seek an advice from
them on how to avoid getting separated with her husband;
3.6 They sought marriage counseling but the problems of the
couple remain unresolved;
IV. FACTS AFTER THE MARRIAGE
4.1 Unknown to the Petitioner, however, Respondent was already
suffering from a psychological incapacity which has already
existed at the time of the celebration of their marriage but
became manifested only later and which was realized by
Petitioner only after the solemnization of their marriage.
4.2 Respondent’s Psychiatric diagnosis showed that he is suffering
from Personality Disorder labeled as Narcissistic Personality
Disorder. A copy of the Psychiatric Evaluation Results is hereby
attached as Annex “D”;
4.3 Based on the Psychiatric Evaluation Result, the Personality
Disorder of the Respondent is serious, incurable and existed
even prior to the parties’ marriage.

PRAYER

WHEREFORE, premises considered it is most respectfully

moved and prayed that this Honorable Court after due notice and
hearing shall issue an order declaring the marriage of the parties on
June 21, 2016 NULL AND VOID.

Petitioner prays for such further relief that may be deemed just
and equitable under the premises.

JUSTICE LEAGUE LAW OFFICES

33 Floor, Cebu IT Park, Apas, Cebu City
rd
 By:

MENCHELL RALPH MARGALLO

PTR No. 1234567 1-5-2012
IBP No. 987243 2-21-11
MCLE Compliance No. III-000123
ROLL NO. 31097 7-10-98

CC:
Office of the Solicitor General
134 Amorsolo St., Legaspi Village,
Makati City, 1229

VERIFICATION AND CERTIFICATION OF NON-FORUM

SHOPPING

I, MS. TMG, of legal age, Filipino, a resident of No. 123, Apas,

Cebu City, after having been sworn to in accordance with law do
hereby depose and state:

1. That I am the petitioner in the above mentioned case;

2. That I have caused the preparation of the amended

petition and read its content which are true and correct of
my own personal knowledge and based on the records on
hand;
 3. That I have not commenced any other action, or
proceeding involving the same issues in the Supreme
Court, the Court of Appeals, or in any court, tribunal or
quasi-judicial agency, and to the best of my knowledge,
no such action or proceeding has been filed or is pending
in the Supreme Court, the Court of Appeals or Divisions
thereof, or any other tribunal/agency. I undertake to
report the fact within five (5) days therefrom to the court
or agency wherein the origin pleading and sworn
certification contemplated therein have been filed.

IN WITNESS WHEREOF, I have hereunto affixed my hand this

1 st
day of February, 2019 at Cebu City.

MS. TMG
Affiant

SUBSCRIBED AND SWORN to before me this 1ST day of

March, 2019 at Cebu City; affiant exhibited her Drivers License No.
____________ issued on _____________ at ____________.

Doc. No. _____;

Page No. _____;
Book No. _____;
Series of 2019.