Republic of the Philippines REGIONAL TRIAL COURT BRANCH 7 Baguio Cit GEORGINA !A"OL# Plaintiff +$e,sus+ RE-BA.

/ELO-O# "efen0ant xxx----------------------------xxx CO!PLAINT 12ith Application fo, Ali3on Pendente Lite4 PLAINTIFF, by counsel and to this Honorable Court, respectfully avers !" Plaintiff is of le#al a#e and $ith residence at %& 'e#idor (treet, Pacdal, )a#uio City $hile defendant is also of le#al a#e and at present residin# at !!* Ca+p Allen, )a#uio City, $here he +ay be served $ith su++ons and other le#al processes, -" Plaintiff is the $ife of defendant, they have been +arried on .ctober !*, -//0 and the +arria#e havin# been sole+ni1ed by Father Alfonso Lacaban of the Holy Fa+ily Church in 2ue1on City" Certified true copy of their +arria#e certificate is attached hereto as Annex 3A4, 5" Plaintiff and defendant have t$o 6-7 +inor children, a#ed 5 and * years old, na+ed (a+son and 8elilah, $ho are livin# $ith plaintiff at the above indicated address" 9nclosed here $ith are their respective )irth Certificates, +ar:ed as Annexes 3)4 and 3C4 respectively, &" .n or about ;une !, -/!/, defendant, $ithout any valid reason, abandoned plaintiff and his t$o 6-7 children" Plaintiff later learned that he $as and still is livin# $ith another $o+an" (ince then, defendant had failed and refused and continues to fail and to refuse to provide financial support and +aintenance to plaintiff and to his t$o children, *" Plaintiff is $ithout any source of inco+e, as she stopped $or:in# $hen she and defendant #ot +arried, to devote her ti+e to her children, $hile defendant is #ainfully e+ployed as <ice President of (t" ;a+es 'ealty Corporation, $here he earns a +onthly salary of (ixty Thousand Pesos 6P =/,///"//7, apart fro+ his co++issions of !/> for real properties he sold, =" To enable plaintiff and her t$o children to eat three ti+es a day, she relied on the benevolence of relatives and friends, 0" Considerin# the defendant?s +onthly inco+e and earnin#s and the cost of livin#, plaintiff and her t$o children re@uire a +onthly support of Thirty Thousand Pesos 6P 5/,///"//7,

Ci$il Case No% &'()*

9i#ht Thousand Pesos 6P A,///"//7 a +onth of $hich $ill be used to pay rentals for the apart+ent in $hich they stay and the balance for daily needs, $hich financial re@uire+ents $ill correspondin#ly increase as the children #ro$ older and their re@uire+ents increase, A" In support of plaintiff?s clai+ for support pendent lite" 9nclosed here$ith are plaintiff?s affidavit, detailin# their daily expenses, lease contract for 9i#ht Thousand Pesos 6P A,///"//7 a +onth for the apart+ent in $hich she and her children live, and other authentic docu+ents, apart fro+ the docu+ents attached as Annexes hereof, $hich are attached as Annexes 384, 394, and 3F4 , respectively"

2HERE5ORE, plaintiff prays for Bud#+ent as follo$s a7 .rderin# defendant provide plaintiff and his t$o children +onthly support pendente lite in the a+ount of Thirty Thousand Pesos 6P 5/,///"//7 a +onth, payable $ithin the first five 6*7 days every +onth startin# April -/!-, b7 After trial, +a:in# defendant?s +onthly support per+anent, $ithout preBudice to its up$ard adBust+ent, dependin# upon plaintiff?s and the t$o children?s needs and the increasin# financial earnin#s of defendant c7 .rderin# defendant to rei+burse plaintiff the a+ount of Five Thousand Pesos 6P *,///"//7 as attorney?s fees and expenses of liti#ation" "ONE this !-th day of Carch -/!- in )a#uio City, Philippines" /ANE--A B% TA8ABAN COUN-EL 5OR PETITIONER (uite 5!/ (anta Luis de )a#uio )ld#" (ession 'oad, )a#uio City 'oll No" =-0/A, *-5!-!/ PT' No" !&*G*G&, !-5-!! )a#uio I)P L" C" No" /&5=A '9PD)LIC .F TH9 PHILIPPIN9( 6 CITE .F )AFDI. 6

("("

/ERI5ICATION AN" CERTI5ICATION I, LEBRON"A 7A!E-, after havin# been s$orn to in accordance $ith la$ hereby depose and state that !" I a+ the Plaintiff in the above-entitled case and have caused the preparation of the co+plaint and have read the fore#oin# alle#ations and sa+e as true and correct to +y :no$led#e and belief, -" I further certify that I have not co++enced any other action, petition or +otion involvin# the sa+e issues in the (upre+e Court other than this action, the Court of Appeals, or any tribunal, or a#ency, and to the best of +y :no$led#e, no such action

or proceedin# is pendin# in the (upre+e Court, Court of Appeals or any tribunal that a si+ilar action or proceedin# has been filed or is pendin# before the (upre+e Court, the Court of Appeals or by any other tribunal or a#ency, $e $ould underta:e to notify the court, tribunal or a#ency $ithin five 6*7 days fro+ such notice"

IN 2ITNE-- 2HEREO5, I have hereunto set +y hand this !-th day of Carch -/!- at )a#uio City" (D)(C'I)98 AN8 (H.'N T. personally before +e this -=th day of ;anuary, -/!- at )a#uio City" Affiant $ho is personally :no$n to +e exhibited to +e her P'C I8 No" /*0&0// under penalty of la$ to the $hole truth of the contents of the fore#oin# docu+ent"

8oc" No" , Pa#e No" , )oo: No" I , (eries of -/!-"

/ANE--A B% TA8ABAN NOTAR8 PUBLIC Notarial Co++ission No" &=-NC-!! 6'7 Dntil 8ece+ber 5!, -/!(uite 5!/ (anta Luis de )a#uio )ld#" (ession 'oad, )a#uio City 'oll No" =-0/A, *-5!-!/ PT' No" !&*G*G&, !-5-!! )a#uio I)P L" C" No" /&5=A CCL9 No" !-5&*=0 Tel" No" &&--&*=0