Support Pendente Lite
Support Pendente Lite
Support Pendente Lite
NOWER MANN,
Defendant
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COMPLAINT
1. Plaintiff and the defendant are wife and husband respectively, having
been married in Jaro Cathedral, Jaro, Iloilo City, on February 14, 2010;
2. That out of this wedlock, two children were born, namely Lucy Mann
and Prudence Mann;
3. Up to March 10, 2016, the marital relations between the plaintiff and
the defendant were harmonious, until March 11, 2016, when it became
known to the plaintiff that defendant allegedly has had extramarital
affairs with a certain Julia Lennon.
4. In view of this infidelity on the part of the defendant, the plaintiff was
compelled to live separately, with her minor children;
5. The defendant earns a fixed monthly income of seventy-five thousand
pesos; while the plaintiff and her children at present only subsist on the
charity of family, relatives, and friends.
6. In view of the necessities of the plaintiff and her minor children, the
sum of thirty-seven thousand five hundred pesos would be reasonable
amount for the support of the plaintiff and her minor children, pendente
lite;
7. Plaintiff, without fault on her part, was compelled to file action for
separate support, thereby having incurred the sum of five thousand
pesos by way of attorney’s fees.
1. Pendente lite, the defendant be ordered to pay the plaintiff the sum of
thirty-seven thousand five hundred pesos per month;
2. After due hearing on the principal cause of his suit, the defendant be
ordered to pay plaintiff by way of regular support and maintenance the
sum of thirty-seven thousand five hundred pesos, payable on or before
the second day of each month;
3. Plaintiff recover from the defendant the sum of five thousand pesos for
attorney’s fees, and the cost of the suit.
3. I have read the contents thereof and the facts stated therein are true and
correct to my personal knowledge and/or on the basis of documents and
records in my possession;
________________________
MARTHA MADEAR
Affiant
TIN 47888-531; Iloilo City
ACKNOWLEDGMENT
all known to me to be the same person who executed the foregoing instrument
and hereby acknowledged to me that the same is their free and voluntary act
and deed.