Republic of the Philippines

REGIONAL TRIAL COURT

7th Judicial Region
Branch 24
Cebu City

MARIA FIDELIS E. VILLALON,

Petitioner,

Versus SPEC. PROC. NO.

For: INDIRECT CONTEMPT

JESUS CHRISTOPHER VILLAVERDE

VILLALON,
Respondent.

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

PETITION FOR INDIRECT CONTEMPT

COME NOW, the Petitioner, through the undersigned counsel, and by way
of Petition for Contempt of Court, most respectfully aver that:

1. Petitioner, MARIA FIDELIS ENCARNACION VILLALON, is of legal age,

Filipino, married and a resident of 6th Street, Tantoco Drive, Happy Valley,
Labangon, Cebu City Philippines, where she may be served with summons
and other processes of this Honorable Court;

2. Respondent, JESUS CHRISTOPHER VILLAVERDE VILLALON, is of legal age,

married, with address at San Jose Village, Umapad, Mandaue City, Cebu
 where he may be served with summons and other processes of this
Honorable Court;

3. This Honorable Court issued an Order dated June 15, 2017 fixing the
amount of monthly support that Respondent should provide to
Petitioner’s son, BRANDON ENCARNACION VILLALON, effective June 2017
in the amount of Twenty-five Thousand Pesos (P25,000.00). A copy of the
Order is hereto attached as Annex “A”;

4. As a consequence of the Order, Respondent filed a Motion for

Reconsideration on July 14, 2017, as shown by, hereto attached copy of
the said Motion for Reconsideration marked as Annex “B”;

5. Petitioner filed its Comment and Opposition to the Motion for

Reconsideration of the Respondent on August 9, 2017 which is attached
herewith as Annex “C”;

6. Respondent then filed a Manifestation dated March 16, 2018, to be

allowed to give support in the lower amount of P8,000.00. Copy of said
Manifestation is hereby attached as Annex “D”;

7. The Court resolved the foregoing Manifestation in its Order dated June 8,
2018, ruling in favor of the Petitioner. Copy of said Order is hereby
attached as Annex “E”;

8. Because of Respondent’s obstinacy to abide and obey the Order of this

Honorable Court, to the prejudice of the herein Petitioner, the latter,
through counsel, filed a Motion to this Honorable Court, to Cite
Respondent in Indirect Contempt; attached herewith as Annex “F”;

9. However, this Honorable Court has denied the Motion in its Order dated
July 6, 2018, as it prefers that charges for Indirect Contempt shall be
commenced by a verified petition with supporting particulars and
certified true copies of documents involved therein, thus, this Petition.
 PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of this

Honorable Court to hold Respondent Jesus Christopher V. Villalon in Indirect
Contempt for not complying the Order of the Court, a clear resistance to the lawful
order and opposition to the authority of this Honorable Court which is highly
contemptible. Holding Respondent in Indirect Contempt is necessary to preserve
the dignity of the court from Respondent’s offensive personalities and
contumacious refusal to comply with the Order.

Such other reliefs just and equitable under the circumstances present are
likewise prayed for.

Most respectfully submitted.

July 19, 2018. Cebu City, Philippines.

MALILONG AND CABATINGAN LAW OFFICES

Counsel for the Petitioner
2/F Don Carlos A. Gothong Port Centre
Quezon Blvd., Pier 4, North Reclamation Area,
Cebu City 6000

By:

CONCEPCION T. CEJANO
Roll No. 70455
IBP No. 042984, 05/28/18
PTR No. 18890290, 06/18/18, Consolacion, Cebu
Admitted to the Bar June 4, 2018
REPUBLIC OF THE PHILIPPINES)
CEBU CITY………………………….)S.S.

VERIFICATION AND CERTIFICATION

OF NON-FORUM SHOPPING

I, MARIA FIDELIS F. ENCARNACION-VILLALON, of legal age, Filipino, and with

address at 6th St., Tantoco Drive, Happy Valley, Cebu City, after having been duly
sworn to in accordance with law, do hereby depose and state, that:

1. I am the Petitioner in the above-entitled Petition for Indirect Contempt. I

have caused the preparation and filing of the same and I have read and
understood the contents thereof, and the allegations therein are true and
correct of my own personal knowledge or based on authentic records.

2. I hereby certify to the best of my knowledge, that no other similar action is

pending in the Supreme Court, the Court of Appeals, or any other court,
tribunal or agency; that if we should hereafter learn that a similar action or
proceeding has been filed or is pending before the Supreme Court, the Court
of Appeals, or different divisions thereof, or any other court, tribunal or
agency, I undertake to promptly inform the Honorable Court within five (5)
days therefrom.

Done this 9th day of July, 2018, Cebu City, Philippines.

MARIA FIDELIS F. ENCARNACION-VILLALON

Affiant

SUBSCRIBED AND SWORN to before me this ________________, Cebu City,

Philippines. Affiant exhibited to me her Competent Evidence of
Identity:____________________.

Doc. No. _____;

Page No._____;
Book No._____;
Series of 2018.