Court]

[Region]
[COURT]
[City], [Branch No.]

[NAME] _____________________,
Petitioner.

-versus- SP No. __________

[NAME] _____________________,
Respondent.

x--------------------------------------------------------x

PETITION

PETITIONER, by counsel, respectfully states that:

1. Petitioner is a Filipino citizen, of legal age and married to respondent. For

purposes of this petition, she may be served with notices and other pertinent processes
through counsel at [ADDRESS OF COUNSEL] ____________________________.

2. Respondent is a Filipino citizen, of legal age, currently employed at [STATE

EMPLOYER] _________________________ and married to petitioner. He may be served with
summons and other pertinent orders and processes of this Court at [STATE ADDRESS]
___________________________________.

3. Petitioner and respondent were married on [DATE] ________________ and out of

this marriage, they have [state number of children, respective ages]. A copy of the Marriage
Contract executed by petitioner and respondent is attached as ANNEX A; a copy each of the
birth certificates of the minor children is attached as ANNEX B, C and D, respectively.

4. Petitioner and respondent are currently separated in fact and have been so since
[STATE MONTH AND YEAR] _______________________. The reason for the continuing
separation in fact is the breakdown of the marriage due to [STATE GROUND FOR SEEKING
DECLARATION OF NULLITY] ____________________________.

5. The mutual psychological incapacity of the parties to remain married to each

other appears to be incurable; prior to this resort, the parties had attempted formal and
informal counseling sessions all of which proved unproductive as respondent proved resistant
and, at times, even hostile to these efforts.

6. [STATE FACTUAL CIRCUMSTANCES PRESENT FOR BOTH PETITIONER AND

RESPONDENT SHOWING GROUND FOR NULLITY OF MARRIAGE INCLUDING ANNEXES;
INCLUDE ALSO PROVISIONAL ORDERS PRAYED FOR AND THE FACTUAL GROUNDS FOR
SEEKING THEIR ISSUANCE] ____________________________________________________.

7. [STATE FACTUAL CIRCUMSTANCES PRESENT FOR BOTH PETITIONER AND

RESPONDENT SHOWING GROUND FOR NULLITY OF MARRIAGE INCLUDING ANNEXES;
INCLUDE ALSO PROVISIONAL ORDERS PRAYED FOR AND THE FACTUAL GROUNDS FOR
SEEKING THEIR ISSUANCE] ____________________________________________________.
 8. [STATE FACTUAL CIRCUMSTANCES PRESENT FOR BOTH PETITIONER AND
RESPONDENT SHOWING GROUND FOR NULLITY OF MARRIAGE INCLUDING ANNEXES;
INCLUDE ALSO PROVISIONAL ORDERS PRAYED FOR AND THE FACTUAL GROUNDS FOR
SEEKING THEIR ISSUANCE] ____________________________________________________.

WHEREFORE, petitioner respectfully prays that PROVISIONAL ORDERS for [CHILD

CUSTODY, SUPPORT PENDENTE LITE, ETC.]
__________________________________________________ and directing respondent to
give monthly support in the amount of [STATE AMOUNT]
______________________________, subject to any adjustments that may be made based
on changing earning capacity as well as needs.

Petitioner also prays that, after trial, judgment be rendered in her favor by declaring
[STATE GROUND RELIED UPON AS BASIS FOR NULLITY OF MARRIAGE]
____________________________________________________________, thus --

[1] Declaring the marriage between petitioner and respondent a nullity and,
by this token, ordering the dissolution of the conjugal partnership of gains;
and

[2] Awarding permanent custody of the children to petitioner, with express

acknowledgement of respondents visitation rights;

[3] Awarding support in the amount of [STATE AMOUNT]

_____________________ subject to adjustments to be made depending on
changes in earning capacity and needs of the children.

All other just and equitable reliefs are also prayed for.

[CITY] ___________; [DATE] _____________.

[SIGNATURE]
[NAME] ______________
Counsel for Petitioners
[ADDRESS] _______________________
IBP Lifetime No. ____________; [CITY] _____________
PTR No. _______________; [DATE], [CITY]
Roll of Attorney No. _______________________
MCLE Compliance No. ____________________

VERIFICATION & CERTIFICATION AGAINST FORUM SHOPPING

I, [NAME] _____________________, of legal age, do hereby state that: I am the

plaintiff in the pleading/document entitled [PLEADING/DOCUMENT BEING VERIFIED]
___________________ and in such capacity, caused this Complaint to be prepared; I have
read its contents and affirm that they are true and correct to the best of my own personal
knowledge; I hereby certify that there is no other case commenced or pending before any
court involving the same parties and the same issue and that, should I learn of such a case,
I shall notify the court within five (5) days from my notice.

IN WITNESS WHEREOF, I have signed this instrument on [DATE]_____________.

[SIGNATURE]
[NAME] _________________
 SUBSCRIBED AND SWORN TO before me in the City of _______________ on this day
of [MONTH AND YEAR]_________________, affiant exhibiting before me his Government
Issued ID no. _______________ issued on [DATE}__________________ at [PLACE OF
ISSUANCE]_____________________.

[SIGNATURE]
[NAME]_______
Notary Public

Until [DATE]__________________
PTR No. [NUMBER] ____________
Issued at [PLACE]______________
On [DATE] ___________________

Doc. No.
Page No.
Book No.
Series of [YEAR] ___________.