Professional Documents
Culture Documents
JOEY DICHOSO,
Petitioner
-versus
FOR:
JENNY H. DICHOSO,
DECLARATION OF NULLITY
Respondent,
OF MARRIAGE
x-------------------------------------------x
PETITION
WITH ALL DUE RESPECT.
Petitioner, by counsel, to this Honorable Court, respectfully
states:
1. Petitioner, JOEY DICHOSO, is of legal age, Filipino citizen and
a resident of Poblacion, Mankayan, Benguet, where he may be
served with summons and other court processes;
2. The Respondent JENNY H. DICHOSO, is likewise of legal age,
Filipino citizen, and a resident of Cypress, Irisan, Baguio City,
where she may be served with summons and other court
processes;
3. Petitioner JOEY DICHOSO and Respondent JENNY H.
DICHOSO (referred as herein as Parties) entered into a
contract of marriage on October 30, 1998 at the Office of the
Municipal Mayor of Alilem, Ilocos Sur, solemnized by Hon.
eight
(8)
years
since
the
Respondent
unceremoniously
abandoned
their
conjugal
home
sometime in 2004;
11. Petitioner tried everything possible to persuade respondent to
change for the better specially her violent personality so that
they could build their family, live together harmoniously as
husband and wife, fulfill their marital vows and discharge their
reciprocal obligation to consummate the essential duties of their
union in order to establish a happy home.
12. However, all such pleas by Petitioner were unheeded as
respondent was not willing to be a wife to him and a mother to
their children. Respondent was not ready to take the
responsibilities and was not prepared to live in a harmonious
and peaceful union with Petitioner;
13. Petitioner engaged a clinical psychologist, Dr. Fhely Layogan,
who conducted a psychological evaluation on the ability of
respondent to cope with the essential obligations of marriage.
After
the
evaluation,
respondent
was
found
to
be
Histrionic
Personality
Disorder
coupled
with
21. That the parties did not acquire any property and there are no
known creditors who will be prejudiced by the declaration of
nullity of their marriage should the Honourable court grants this
petition, hereto attached as Certificate of Non-Property,
Annex F.
PRAYER
WHEREFORE, it is most respectfully prayed that judgment be
rendered declaring the nullity of the marriage of Petitioner with the
Respondent pursuant to Article 36, and the annulment of the same
marriage based on Article 45 (5) of the Family Code of the
Philippines.
Other reliefs and equitable under the premises are also prayed
for.
January 30, 2015 Baguio City, Philippines
LK LAW FIRM
Suite 204, Puso ng Baguio
Session Road, Baguio City
By:
DIAMOND SUPNET KELSCH
IBP: 994543, 2/17/13, Baguio City
PTR No. 23434, 1/16/13; Baguio City
Roll No. 34534, 4/8/12; Manila
MCLE Compliance No. IV-443456, 7/7/14; Baguio City
Telefax No. (074) 442 -3495-08653, Mobile no. 09173435235
LAUREL LIMNMAYOG
IBP: 99434543, 2/17/12, Baguio City
PTR No. 23434, 1/16/12; Baguio City
Roll No. 34534, 4/8/11; Manila
MCLE Compliance No. IV-45546, 7/7/14; Baguio City
Telefax No. (074) 442 -3495-08653, Mobile no. 09394354456
Copy Furnished:
Office of the City Prosecutor (Personal Service)
Justice Hall, Baguio City
EXPLANATION
A copy of the foregoing PETITION was sent through registered mail
to the office of the Solicitor General due to the distance, and
manpower constraints.
VERIFICATION/CERTIFICATION
I, JOEY DICHOSO, of legal age, married, Filipino, and a
resident of Poblacion, Mankayan, Benguet , after being duly sworn in
accordance with law, depose and state:
1. That I am the petitioner in this case and that I have caused the
preparation of the same petition;
2. That I attest to the truth of all the allegations in the same petition of
my own personal knowledge;
3. That I have read all the contents thereof;
4. That the allegations constrained therein are true and correct of my
personal knowledge
5. That I have not commenced any other action or proceeding involving
the same issues or matter in any court, tribunal or quasijudicial agency and, to the best of our knowledge, no such
action or processing is pending therein,
6. That if I should thereafter learn that the same or similar action or
proceeding has been filed before the Supreme Court, Court
of Appeals, or any other tribunal or quasi-judicial agency, I
undertake to report such within five (5) days therefrom to the
court wherein the original pleading and sworn certification
contemplated herein has been filed
IN WITNESS WHEREOF, I have hereunto set my hand this 18
day of January 2015 in the City of Baguio.
JOEY DICHOSO
Affiant
Social Security System No. 23455345643
Issued in Baguio City
SUBSCRIBED AND SWORN to before me this 18 day of
January 2015 at Baguio City, Philippines, by affiant who exhibited
competent evidence of identity bearing his photograph and signature
the specifics of which are indicated below his names