REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
CITY OF MANILA
BRANCH ___

MARIA LUISA RAMOS

Petitioner,

Civil Case No. ______________

-versus- FOR: Judicial Declaration of
Nullity of Marriage

MACARIO DE MESA,
Respondent.
x------------------------------------------------------------------x

MOTION TO LITIGATE AS INDIGENT LITIGANT

COMES NOW, the petitioner, MARIA LUSIA RAMOS,

through the undersigned counsel and unto this Honorable Court, most
respectfully avers that:

1. At present, the petitioner is jobless, has no means of livelihood

and cannot afford to pay the required docket fee. Attached is the Affidavit of
the Petitioner to being an indigent as “ANNEX A”.

2. Also, attached with this Motion is the affidavit of two

disinterested persons attesting to the truthfulness of Maria Luisa Ramos’
affidavit as “ANNEX B”.

3. Petitioner now comes to this Honorable Court and respectfully

move that she be allowed to litigate as indigent litigant, and be exempted
from the payment of the required docket fees and other lawful fees.
 PRAYER

WHEREFORE, premises considered, it is respectfully prayed of this

Honorable Court that the petitioner be allowed to litigate as indigent litigants
and be exempted from the payment of the required docket fees and other
lawful fees.

Other reliefs just and equitable under the premises are likewise prayed
for.

Makati City for Manila,2 October 2019

PEREZ LAW FIRM

Counsel for Petitioner
17 Floor, Suite 1709, Sky Building
TH

Salcedo St., Makati City

Telephone No. (632) 8663716
E-mail address thefirm@PerezLawFirm.ph

By:

LORENZO A. PEREZ
PTR No. A-11593229/1.11.2019/Makati City
IBP No. 11593229/1.14.2019/Tuguegarao
Roll No. 11593229
MCLE Compliance No. V-11593219
Issued April 25, 2016
Tel. No. (02) 866-3716
Cell Phone No. 09172552565
Email Address: LP@PerezLawFirm.ph
 NOTIFICATION

OFFICE OF THE CLERK OF COURT

Regional Trial Court, Manila
4th Floor, Manila City Hall, Manila

Greetings:

Please submit the foregoing Motion to Litigate as Indigent Litigant

and for the consideration and approval of the Honorable Court immediately
upon receipt hereof.

ATTY. LOREZNO A. PEREZ

CC:
MR. MACARIO DE MESA
789 Martinez Street, Mandaluyong City

EXPLANATION OF SERVICE

Copy of the Motion to litigate as pauper litigant was served to

respondent by registered mail due to time and distance constraints, and for
lack of the undersigned’s staff who can serve the same in person.

ATTY. LOREZNO A. PEREZ

 “ANNEX A”
REPUBLIC OF THE PHILIPPINES)
______________________________ ) S.S.

SWORN STATEMENT OF PETITIONER

I, MARIA LUISA RAMOS, of legal age, Filipino, with address at 12345

TAFT AVENUE, MALATE, MANILA, PHILIPPINES, after having been duly
sworn to in accordance with law hereby freely depose and say that:—
1. I am resident of 12345 Taft Avenue, Malate, Manila

2. My gross income and that of my immediate family does not exceed

TWENTY SEVEN THOUSAND NINE HUNDRED TWENTY FOUR
PESOS (P27,924.00);

3. I do not own real property with an assessed value of more than

THREE HUNDRED THOUSAND PESOS (P300,000.00) as shown by
the attached Certification issued by the Office of the
City/Municipal Assessor and the City/Municipal Treasurer’s
Office;

4. Due to financial constraint, I cannot afford to pay for the expenses

of a court litigation as I do not have enough funds for food, shelter
and other basic necessities;

5. Should the court render judgment in my favor, the amount of the

docket and other legal fees which I was exempted from paying
shall be a lien on the judgment, unless the court orders otherwise.

IN WITNESS WHEREOF, I have hereunto affixed my signature this

2 October 2019, at Makati City, Philippines.

MARIA LUSIA RAMOS

Affiant

SUBSCRIBED AND SWORN to before me this 2nd day of October 2019

in Makati City, Philippines, affiants exhibiting to me their Tax Identification
Cards with TIN No. 123789 for MARIA LUSIA RAMOS

ATTY.CRICHELLE ANNE Q. SY
NOTARY PUBLIC

Doc. No.:
Page No.:
Book No.:
Series of 2019

“ANNEX B”
REPUBLIC OF THE PHILIPPINES)
______________________________ ) S.S.

JOINT AFFIDAVIT OF TWO DISINTERESTED PERSONS

WE, NICO ACABADO and THEODORE DOLAR both of legal

ages, Filipino and with residence addresses at UNIT 19C WH TAFT
RESIDENCES, TAFT AVENUE, MALATE, MANILA and UNIT 2705
EGI TAFT TOWERS, TAFT AVENUE MALATE, MANILA,
respectively, after having been jointly sworn to in accordance with law do
hereby depose and state, that:

1. We personally know the person of MARIA LUISA RAMOS, a

resident of 12345 Taft Avenue, Malate, Manila;

2. This affidavit was executed to attest to the truthfulness of MARIA

LUSIA RAMOS’ Affidavit of Indegency;

3. We know for a fact that MARIA LUSIA RAMOS’ gross income does
not exceed TWENTY-SEVEN THOUSAND NINE HUNDRED TWENTY
FOUR PESOS (P27,924.00);

4. Furthermore, we know for a fact that MARIA LUSIA RAMOS deos

not own real property with an assessed value of more than THREE
HUNDRED THOUSAND PESOS (P300,000.00);

5. That we are executing this affidavit to attest to the foregoing narration

of facts and for whatever legal purposes and intents this may serve.

IN WITNESS WHEREOF, I have hereunto affixed my signature this

2 October 2019, at Makati City, Philippines.

NICO ACABADO THEODORE DOLAR

Affiant Affiant

SUBSCRIBED AND SWORN to before me this 2nd day of October 2019

in Makati City, Philippines, affiants exhibiting to me their Tax Identification
Cards with TIN No. 123789 for MARIA LUSIA RAMOS

ATTY.CRICHELLE ANNE Q. SY
 NOTARY PUBLIC
Doc. No.:
Page No.:
Book No.:
Series of 2019