Republic of the Philippines

7th Judicial Region

Regional Trial Court
Branch 52
Talibon, Bohol

MA. JULIETA S. HAKLOB

Petitioner,
CIVIL CASE No: _____________
FOR: Declaration of Nullity of
Marriage under Art. 36 of the
-versus- Family Code

EDILBERTO L. HAKLOB
Defendant,
x- - - - - - - - - - - - - - - - - - - - - - - - - x

PETITION

COMES NOW petitioner, through the undersigned counsel and to

this Honorable Court, respectfully alleges:

1. That petitioner MA. JULIETA S. HAKLOB is of legal age,

married, Filipino and resident of Poblacion, Ubay, Bohol;

2. That respondent EDILBERTO L. HAKLOB is likewise of legal age,

married, Filipino and presently residing at Tipolo, Ubay, Bohol;

3. That petitioner and respondent celebrated their marriage on

November 18, 2005 before the Parish Church of Ubay, Bohol, certified
true copy of their Marriage Certificate is attached and made integral part
hereof as Annex “A”;

4. That petitioner and respondent have two children. They have no

written agreement executed before the marriage to govern their property
relations or have any community property acquired during their
marriage. They have no debts;

5. That petitioner met the respondent sometime in 2000 in City of

Tagbilaran. Their romance culminated in a marriage before the priest of
Ubay Catholic Church in Ubay, Bohol;

6. That in a short span of time they had been together, this is the
time which the petitioner describes as a period where the respondent’s
instability, psychological or otherwise, showed up;

7. That other instances, wherein such instability could be

reasonably inferred are as follows:

a. Two (2) months after their marriage, the respondent gave up

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his job at Philippine National Bank as Bank Teller without justifiable
reason;

b. That petitioner tried to explain to him that it was his

responsibility to support her but respondent would ignore and shout at
her, making the petitioner the breadwinner of the family;

c. That the respondent is a compulsive gambler;

d. He is a womanizer;

e. He resorts to drug and alcohol abuse during their

cohabitation;

f. That the respondent does not want to have a child with the
petitioner because according to him it will just cause burden for him;

g. That parties would fight even for the smallest things through
not due to the fault of the petitioner, and frequently, the respondent
would always apologize to the petitioner, but later on, he will repeat his
quarrelsome and troublesome ways;

h. He prefers to hang out with friends and with her flings instead
of being with petitioner;

8. That during their honeymoon period, things was running smoothly

between them, but not on the succeeding months, when the respondent’s
instability started to manifest clearly to the petitioner. Their relationship
lasted sometime in 2014;

9. That some other manifestations of the psychological and emotional

disturbances on the part of the respondent can be cited as follows:

a. That there were many times when the respondent never even
kissed the petitioner. Respondent would not even look at her whenever
they spoke with each other. She was always the one, who holds or hugs
him so that they may become closer to each other but every time she
tries to be closer to him, he simply had to always turn his back to her.
This is causing so much unbearable emotional and psychological pain on
the part of the petitioner;

b. That petitioner told the respondent that they should discuss

what went wrong between them and hopefully they could work it out
again. The petitioner verbalized all of the things she had noticed and
felt, knowing that everything works out when there is an open
communication. She told him about the lack of passion, respect and
romance in their relationship. The respondent just ignored her pleas;

c. That respondent began hurting the petitioner physically by

throwing things on her and shoving her around;

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 d. That respondent did not stop gambling and using alcohol
and drugs;

e. The respondent abandoned the petitioner and left to be with

another woman. Since November 2014, the respondent did not return
nor tried to communicate with the petitioner. The petitioner on several
instances, tried to reach the respondent through his relatives and friends
but to no avail.

10. That the petitioner already gave up on the respondent after trying
to give all her efforts just to save her marriage to a man who, as shown in
the foregoing, is not cognitive to and psychologically incapable of
performing, his basic marital covenants to herein petitioner;

11. That further, respondent’s psychological incapacity from all

indications appears to have been manifesting at the time of the
celebration of marriage. Although said manifestations were not then
perceived, the root cause shall be proved to such an extent that
respondent could not have known the obligations he was to fulfill or
knowing them could not have validly performed them. It is of such
incapacity that respondent was unable to assume his marital obligations;

12. That the respondent’s incapacity to fulfill his essential marital

obligations appear to be grave, incurable and deeply ingrained, thus;
warranting the issuance of the Decree of Nullity of petitioner’s marriage
with the respondent;

13. That finally, the petitioner has therefore no other recourse but to
seek judicial relief. The prospects or possibility of respondent to reform
and assume his essential marital obligations is a remote possibility, if
not a hopeless expectancy.

PRAYER

WHEREFORE, after trial, it is respectfully prayed that this

Honorable Court rendered judgment:

1. Declaring the marriage entered into by the parties as NULL

and VOID on the ground of psychological incapacity of the respondent;

2. Ordering the Local Civil Registrar and the National Statistics

Office to cancel in their respective Books of Marriages, the marriage
between the petitioner and the respondent.

Petitioner prays for such other relief she may be entitled to in the
premises.

Talibon, Bohol, Philippines. 4th day of February 2019

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 KIM GERONIMO B. FUENTES
Counsel for the Plaintiff
Roll of Attorneys No: 69355
IBP No: 25771/ Bohol/01-2-19
PTR No: 20001462/01-24-19
MCLE Compliance No: VII-1520021/02-23-18

VERIFICATION-CERTIFICATION
ON NON-FORUM SHOPPING

I, MA. JULIETA S. HAKLOB, of legal age, Filipino citizen, resident

of Poblacion, Ubay, Bohol, after having been sworn to in accordance with
law, depose and say:

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

2. That I caused the preparation and filing of the foregoing Petition;

3. That all the allegations therein are true and correct of my own
knowledge and based on authentic records;

4. That I hereby certify under oath that I have not heretofore

commenced any other action or proceeding involving the same issues in
the Supreme Court, Court of Appeals or any other tribunal or agency,
and that to the best of my knowledge, there is no other action or
proceeding, which is pending before this Honorable Court, Court of
Appeals, Supreme Court or any other tribunal or agency involving the
same parties and the same issues, and that if I learn hereafter that there
are other proceedings pending before this Honorable Court, or any other
tribunal or agency, I hereby undertake to report that fact within five (5)
days therefrom to this Honorable Court.

Ubay, Bohol, Philippines, February 4, 2019.

MA. JULIETA S. HAKLOB

SUBSCRIBED AND SWORN to before me this 4th day of February,

2019 at Ubay, Bohol, Philippines. Affiant exhibited to me her Philippine
Passport No. 78238 issued at Cagayan De Oro City.

Doc No.10 KIM GERONIMO B. FUENTES

Page No. 14 Poblacion, Ubay, Bohol
Book No. 2 Roll of Attorneys No: 69355
Series of 2019 IBP No. 25771, Bohol, January 15, 2019
PTR No: 2001462, January 15, 2019
MCLE Compliance No. VII -1520021/02-23-18

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