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Republic of the Philippines

SECOND JUDICIAL REGION


REGIONAL TRIAL COURT
Branch ___
Bayombong, Nueva Vizcaya

SONIA C. CASTILLO,
Petitioner, CIVIL CASE NO.______
FOR: ANNULMENT OF MARRIAGE
-versus-

NARCISO C. LALLBAN, JR.


Respondent.

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

PETITION

COMES NOW, petitioner through the undersigned counsel and unto the
Honorable Court, most respectfully avers, that:

1. Petitioner is of legal age, married, Filipino and a resident of San Fernando


Road, Calaocan, Bambang, Nueva Vizcaya while respondent is likewise of
legal age, married, Filipino and a resident of San Eugenio, Aringay, La Union,
where summons and other processes of the Honorable Court may be served;

2. Sometime in 1995 while I was a Domestic Helper at Taipe, Taiwan, a brother


of respondent befriended me and asked me to be introduced to his brother as
a penpal friend and thereafter respondent wrote me a letter introducing himself
and asked that we become friends. I positively responded to his offer of
friendship and our communication became regular;

3. That through written communication, we pledged to love one another and


through the years, our communication continued;

4. That on June 1999, I returned to the Philippines and we met at Manila and
decided to get married so that on June 15, 1999 we married at the Spiritual
Filipino Catholic Church at Magtanggol St., Caloocan City, a photocopy of
the Certificate of Marriage is hereto attached and marked as Annex A;

5. Because we were not financially prepared to raise a family and to familiarize


ourselves to one another, we agreed to refrain from any sexual contact so that
after the marriage, we parted ways and I applied as a Domestic Helper in Italy
on July 1999;

6. Our communication continued for sometime but as the months went by, our
communication became lesser as he did not respond regularly;
7. Sometime on May 2004, I returned to the Philippines now financially and
emotionally ready to raise a family with my beloved husband;

8. Some of my relatives and my husband welcomed me back home and after a


sumptuous dinner dinner, my relatives went away. My husband and I
proceeded to a hotel somewhere in Ermita but to the surprise of my life, he
refused to have sex with me even as I wore my special night gown. I asked
him if there is something wrong but he refused to answer which made me
suspect that he may be impotent. I got frustrated and mad because he refused
to communicate or respond. I slept because I was tired and after a few hours,
I woke up and he was no longer around. For a while, I was devastated and I
did not know what to do in my life. After working so hard and saving my
salary for many years, all will go waste. In the midst of my suffering, my
friends consoled me and advised me to move on but I could not move on as I
was emotionally and psychologically suffering from the failed relationship.

9. While in Manila, my friends invited me to attend several social outings and


mostly we joined drinking sprees. On one occasion, I was somewhat
inebriated and something happened between me and a male companion;

10. On June 2004, I returned to Italy and I was shocked when I discovered that I
was pregnant because my monthly period stopped. I was so worried what to
do with my pregnancy but in the end I decided to keep my baby;

11.Sometime on November 4, 2004, I returned to the Philippines to wait for the


delivery of my baby and on January 31, 2005 my daughter Erich Castillo was
born at Bayombong, Nueva Vizcaya. A photocopy of her Certificate of Live
Birth is hereto attached and marked as Annex B;

12.Two months after the birth of my daughter, I returned to Italy and left my baby
at the custody of my mother and sister at Watwat, Kasibu, Nueva Vizcaya;

13.I was forced to return to Italy in order that I can support the sustenance and
education of my only daughter;

14.Later, I learned through some friends that respondent has a family and now
living in San Eugenio, Aringay, La Union;

15.That due to the foregoing facts, I intend also to get married but I am still
legally married to respondent, hence, this petition.

WHEREFORE, premises considered, it is most respectfully prayed of the


Honorable Court, that the marriage contract be annulled or declared null and void
for lack of consummation amounting to psychological incapacity.

Petitioner prays for such other relief and remedies consistent in the premises.

Bayombong, Nueva Vizcaya, August 14, 2017.


PAWINGI AND ASSOCIATES LAW OFFICE
JBM Bldg., National Road, Bayombong, Nueva Vizcaya
Counsel for Petitioner

By:

ATTY. PRESLEY JOHN L. NAMINGIT


Roll. No. 69260 5/31/2017
IBP No. 003830 5/11/2017
MCLE Compliance Exempt
(New Lawyer)

CERTIFICATION AND VERIFICATION

I, SONIA C. CASTILLO, of legal age, married, Filipino citizen and a


resident of San Fernando Road, Calaocan, Bambang, Nueva Vizcaya, after having
been sworn in accordance with law, do hereby depose and state:

That I am the petitioner in the above-entitled petition and I caused the


preparation of the petition;

That the allegations thereof were supplied by me and I have read said
allegations and they are true and correct of my own personal knowledge and
belief;

That I have not commenced any action involving the same issues and parties
before any court of justice in the Philippines, administrative or agencies of the
government and should I learn of any such action, I will inform the court
within five (5) days from knowledge thereof.

SONIA C. CASTILLO
Petitioner

SUBSCRIBED AND SWORN to before me at Bayombong, Nueva Vizcaya


this __ day of August 2017. Petitioner exhibited her Passport No. EC0534707 known
to me to be the same person who executed the foregoing Petition.

Doc. No. _____


Page No. _____
Book No. _____
Series of 2017

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