Complaint----Page 1 of 4

Republic of the Philippines

8TH Judicial Region
Regional Trial Court
Branch_____
Tacloban City

Fatima N. Alonzo
Plaintiff, CIVIL CASE No. _______________
FOR: SUPPORT

-versus-

Celso M. Melgar
Defendant.
x-------------------------------------------------x

COMPLAINT

COMES NOW, the Plaintiff, through the undersigned counsel unto

this Honorable Court, respectfully avers:

I. THE PARTIES

1. That plaintiff is of legal age, Filipino, and a resident of Brgy.

San Jose, Tacloban City where she could be served with
summonses and orders of this Honorable Court;

2. That defendant is also of legal age and residing at Brgy.

Caibaan, Tacloban City, where he could be served with
summonses and other orders of this Honorable Court;

II. ANTECEDENT FACTS

3. That plaintiff and defendant had a romantic relationship

which resulted in the birth of Matt, now 12 years old, an
illegitimate child. A certified true copy of the certificate of live
birth, signed by the defendant, is herein attached as “ANNEX
A” and made an integral part hereof;

4. That defendant freely acknowledged the paternity of Matt as

evidenced by the Certificate of Live Birth as well as numerous
photographs showing the former with his son;
 Complaint----Page 2 of 4

5. That defendant stopped giving support when their son was

just about one (1) year old;

6. That plaintiff spends the amount of Php10,000 a month to

sustain her son’s needs including providing for groceries,
clothing and school materials. As evidence thereof, copies of
the grocery, clothing and school material receipts for the
month of July 2019 are herein attached as ANNEX “B”, “C”
and “D” respectively and made an integral part hereof.

7. That plaintiff’s son, Matt, is currently enrolled as a Grade 7

student of Leyte National Highschool in which plaintiff pays
a miscellaneous of Php500. A copy of the official receipt is
herein attached as “ANNEX E” and made an integral part
hereof;

8. That plaintiff is a sales agent of Robinsons Appliance and her

employment therein is her only source of income with a gross
monthly compensation of TEN THOUSAND PESOS
(Php10,000). A copy of the pay slip is herein attached as
“ANNEX F” and made an integral part hereof;

9. That defendant, on the other hand, is employed as a banking

manager of BDO Rizal Avenue Branch, earning gross
monthly compensation of FORTY THOUSAND PESOS
(Php40,000). A copy of the Certificate of Employment and the
pertinent monthly pay slip are herein attached as ANNEX
“G” and “H” respectively and made an integral part hereof;

10.On February 14, 2019, a formal letter to demand support was

sent to defendant’s last known home address through
personal service but this was left unanswered. As evidence
thereof, a photo of the letter in which defendant affixed his
signature right after it was delivered to him is herein attached
as “ANNEX I” and made an integral part hereof;

11.That defendant, despite having the means and capacity to

give financial support, with deliberate intent, did then and
there committed acts of economic abuse against the plaintiff
and her minor son by depriving them of financial support,
which caused mental or emotional anguish, public ridicule or
humiliation to plaintiff and her son;
 Complaint----Page 3 of 4

III. PRAYER

IN VIEW OF THE FOREGOING, plaintiff respectfully prays

that judgement be rendered against defendant ordering the
latter to pay plaintiff:

1. A monthly allowance of Php10,000 to be paid on or

before the 1st day of every month;

2. After trial, ordering the said monthly support to be

made permanent;

3. The amount of FIFTY THOUSAND PESOS by way of

Attorney’s fees and costs of litigation.

4. The amount of SEVENTY-FIVE THOUSAND PESOS

by way of moral damages.

All other remedies, just and equitable are also prayed for.

RESPECTFULLY SUBMITTED. Tacloban City. August 23, 2019

ATTY. NIZA APRIL PORTEZA

PORTEZA, RAÑIN, SON Law Office
Counsel for the Plaintiff
Taft St., Tacloban City.
IBP No. 1234 /01-09-19/ Tacloban City
PTR No. 5678910/1-09-19/Tacloban City
MCLE No. I-0012345/ April 8, 2019
Roll of Atty.’s No. 59785, April 1, 2019

Copy Furnished: (By Personal Service)

Celso M. Melgar
Brgy. Caibaan, Tacloban City

Registry Receipt No. ____________________ Dated: _______________

 Complaint----Page 4 of 4

VERIFICATION/CERTIFICATION OF NON-FORUM SHOPPING

Republic of the Philippines)

Tacloban City…………………….) S.S.
X------------------------------ X

I, FATIMA N. ALONZO, Filipino, of legal age, single and a

resident of Brgy. San Jose, Tacloban City, Leyte Philippines, after being
duly sworn in accordance to law, hereby depose and say;

1. That I am the PLAINTIFF in the above-entitled case; I have

caused the preparation and filing of the foregoing COMPLAINT; I
have read and fully understood the contents of the same and the
contents hereof are true and correct to my personal knowledge and
based on authentic records;

2. That I have not commenced any other action or proceeding

involving the same issues before the Court of Appeals, or the Supreme
Court or any other tribunal or agency and to the best of my knowledge
and belief, I understood that I must state the status thereof; and if
should I thereafter 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 that fact within five
days therefrom to the Honorable Court wherein the original pleading
and sworn certification contemplated herein have been filed. IN
WITNESS WHEREOF, I hereunto set my hand this August 23, 2019 in
Tacloban City, Leyte, Philippines.

FATIMA N. ALONZO
Affiant

SUBSCRIBED AND SWORN TO before me this August 23, 2019 in

Tacloban City, Philippines, affiant acknowledging to me that the same
is her voluntary act and she personally showed to me her competent
evidence of identity being her POSTAL ID No. A11-V-2255.

Doc No. ________ ATTY. NIZA APRIL PORTEZA

Page No. ________ Notary Public until December 31, 2019
Book No. _________ IBP No. 1234 /01-09-19/ Tacloban City
Series of 2019. PTR No. 5678910/1-09-19/Tacloban City
MCLE No. I-0012345/ April 8, 2019
Roll of Atty.’s No. 59785, April 1, 2019