Complaint - GAWAT

Republic of the Philippines
REGIONAL TRIAL COURT

Batangas City
HUWAGKANAMAGALIT BABY,
Plaintiff,
- Versus - Civil Case No. 1234

For: Declaration of Nullity of Marriage
PAUWI NAAKO-BABY,
Defendant.
X-----------------X
COMPLAINT
COMES NOW Plaintiff, by the undersigned counsel and unto this Honorable
Court, most respectfully alleges that:
1. Plaintiff HUWAGKANAMAGALIT BABY of legal age, married, Filipino and

with residence and postal address at 11 Boom Panes St., Batangas City;
2. Atty. Ron Gawat is the counsel of Plaintiff with office address at 12

Ansaveh St., Batangas City, where notices and issuances of the Court may
be sent;
3. Defendant PAUWI NAAKO-BABY is of legal age, married, Filipino, and with

residence and postal address at 13 Marites St., Batangas City;
4. On September 1, 2015, marriage between the defendant and plaintiff was

officiated;
5. A child was born in wedlock, AYLAVYU BABY, aged aged 6 years old, a
copy of Certificateof Live Birth is hereto attached as Annex “B”;
6. After 2 years in the marriage, the defendant was caught having an illicit
relationship with her colleague, AKIN KALANG;
7. The relationship between plaintiff and defendant while at the start was
normal, was subsequently seriously marred with irreconcilable
differences, incompatibility and serious quarrels brought about by
defendant’s immaturity and incapacity to perform her marital obligation
to the plaintiff;
8. Thereafter, the plaintiff and defendant always fight because of defendant’s

unreasonable jealousy and defendant always utters vindictive words and
sometimes result to physical abuse;
9. The defendant’s actuation taken as a whole, manifest inability to perform

essential marital obligations which inability is determined to be
psychological in origin;
10. The incapacity of the defendant is so grave and appears to be
incurable and a clear manifestation that could be clinically identifiable
which put to serious doubt the validity of their marriage;
11. The defendant’s whereabouts became unknown for almost 2 years;
PRAYER
WHEREFORE, in view of the foregoing, plaintiff prays that immediately after

the filing of the Complaint, the Honorable Court orders the defendant to pay
support pendente lite in the amount of TWENTY THOUSAND PESOS a month,
while the case is pending.
Thereafter, and after due hearing, it is respectfully prayed that the

Honorable Court renders judgment as follows:
1. Declaring the marriage between plaintiff and defendant null and void ab
initio under the provisions of Article 36 of the Family Code of the
Philippines;
2. Confirming permanent custody of the minor child, AYLAVYU BABY in
plaintiff;
3. Adjudicating all other legal effects of the decree of nullity of marriage.
Other just and equitable reliefs are likewise prayed for.
Batangas City, July 18, 2022.
Atty. RON GAWAT

A.M. 287 Until 31 December 2022, Batangas City
Roll No. 09721 / IBP Lifetime Member No. 4342 / 09-23-19
PTR No. SJ 7863728 / 11-09-19 /SJ
MCLE VII 78637 valid until 30 Nov 2022
Batangas City / Tel Number (02) 8024908
[email protected]
VERIFICATION AND CERTIFICATION AGAINST FORUM SHOPPING
I, HUWAGKANAMAGALIT BABY, of legal age, married,

Filipino and with residence and postal address at 11 Boom Panes St.,
Batangas City, after having been duly sworn on accordance with law depose
and say:
1. That I am the PLAINTIFF in the above-entitled COMPLAINT;

2. That I have read the allegation therein and certify that the same are
true and correct of my own personal knowledge;
3. That I further certify that I have not commenced any other action
involving the same issues before the Supreme Court, Court of Appeals
or any division thereof or any tribunal or agency; and to the best of my
knowledge no such action is pending before the Supreme Court, Court
of Appeals or any division thereof or any tribunal or agency;
4. That in the event that any action involving the same should be made
known, I hereby bind myself to report the same within five (5) days from
knowledge thereof to this Honorable Court.
(sgd)
HUWAGKANAMAGALIT BABY
Affiant
WITNESSES
Petitioner affixed his Thumbmark in the presence of the following

witnesses:
(sgd) (sgd)
Violet Chachki Sharon Needles
SUBSCRIBED AND SWORN TO before me at Manila City, this 18th day of

July 2022, by the above-named petitioner, who has satisfactorily proven to me
his identity through his (ID Number and Expiry Date), who is the same person
who personally presented and personally signed before me this (State the name
of document) and attested that the contents thereof are true and correct; and
that he voluntarily executed the same.
Atty. RON GAWAT

A.M. 287 Until 31 December 2022, Batangas City
Roll No. 09721 / IBP Lifetime Member No. 4342 / 09-23-19
PTR No. SJ 7863728 / 11-09-19 /SJ
MCLE VII 78637 valid until 30 Nov 2022
Batangas City / Tel Number (02) 8024908
[email protected]
Doc. No.12;
Page No. 34;
Book No. 56;
Series of 2022.

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Republic of the Philippines

REGIONAL TRIAL COURT

- Versus - Civil Case No. 1234

1. Plaintiff HUWAGKANAMAGALIT BABY of legal age, married, Filipino and

2. Atty. Ron Gawat is the counsel of Plaintiff with office address at 12

3. Defendant PAUWI NAAKO-BABY is of legal age, married, Filipino, and with

4. On September 1, 2015, marriage between the defendant and plaintiff was

8. Thereafter, the plaintiff and defendant always fight because of defendant’s

9. The defendant’s actuation taken as a whole, manifest inability to perform

11. The defendant’s whereabouts became unknown for almost 2 years;

WHEREFORE, in view of the foregoing, plaintiff prays that immediately after

Thereafter, and after due hearing, it is respectfully prayed that the

Other just and equitable reliefs are likewise prayed for.

Batangas City, July 18, 2022.

Atty. RON GAWAT

VERIFICATION AND CERTIFICATION AGAINST FORUM SHOPPING

I, HUWAGKANAMAGALIT BABY, of legal age, married,

1. That I am the PLAINTIFF in the above-entitled COMPLAINT;

Petitioner affixed his Thumbmark in the presence of the following

SUBSCRIBED AND SWORN TO before me at Manila City, this 18th day of

Atty. RON GAWAT

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