Legal Writing Pleading
Legal Writing Pleading
Legal Writing Pleading
OLIVIA M. REYES-ARNAIZ,
Respondent.
X-------------------------X
PETITION
02. Petitioner and respondent are husband and wife, having been
legally married on June 7, 2015 at Sta Ana Parish Church, in Lapu-
Lapu St., Poblacion District, Davao City, a copy of their marriage
certificate is hereto attached as Annex A;
03. A child was born in wedlock, Arvin R. Arnaiz, aged 2 years old, a
copy of his Certificate of Live Birth is hereto attached as Annex B;
Page 02.
05. Aside from being officemates, they were likewise attracted to
each other physically. Although there were no emotional
attachments to one another, they frequently indulged in sexual
intimacies of which resulted in respondents pregnancy. Petitioner
did not want to marry respondent for he knew her to be a playgirl,
having had a long list of boyfriends. He however vowed to support
their child.
09. Before his tourist visa expired, petitioner came back to the
Philippines and attempted to reconcile with respondent especially
after seeing his baby. Respondent refused to live again with
petitioner. He was resigned to just visiting his baby boy from time to
time and giving financial support to their child.
10. Time went by with the parties living separately on their own. It
became convenient for both to live separately as they would
constantly fight when they are together. Soon petitioner got
employed with a construction job owned by his relatives.
Respondent too became gainfully employed. Distance and separation
drove both petitioner and respondent to have their respective lovers.
Page 03.
12. While abroad, he not only studied but worked as well, taking in
odd jobs to support himself and his family. In 2006, it was
respondents turn to go abroad to work in Taiwan. Petitioner and
respondent used to communicate thru text messaging and they both
agreed to come home.
13. Petitioner came back in January 2008, not long after, respondent
came home too. They both decided to try and live together again as a
family. Unfortunately, since both of them distrust each other, they
frequent arguments and disagreements. Worse, petitioner found out
that respondent had a boyfriend in Taiwan, who had remained in
touch with her. And worst, respondent had not severed her
relationship with him, thus, the guy maintained communications
with her. This was the last straw that broke the camels back, so to
speak.
14. To date, they have gone separate ways and there is no hope for
reconciliation.
Page 04.
19. That petitioner and respondent have not acquired any real
properties in the course of their marriage.
PRAYER
VERIFICATION
I, PETER PAUL S. ARNAIZ, of legal age, under oath, states:
01. That I am the petitioner in this case and that I have caused the
preparation of the same petition;
02. That I attest to the truth of all the allegations in the same petition
of my own personal knowledge;
Page 05.
Affiant