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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT


FOURTH JUDICIAL REGION
BRANCH ……
BINAN, LAGUNA

DESIREE M. NAVARRO &


GLADISE M. NAVARO,
Petitioners,

- versus - JDRC # ……….


For: Support with Damages
CABRINE L. NAVARRO,
Respondent.
x-------------------------------x

PETITION FOR SUPPORT

COME NOW, PETITIONERS, through the undersigned counsel, and unto this

Honorable Court, most respectfully state the following: THAT:

1.) PETITIONER DESIREE M. NAVARRO is of legal age, Filipino, married

to RESPONDENT CABRINE L. NAVARRO and presently residing at Blk. 11, Lot

11, Souhtville 5, St. Joseph Village, Brgy. Timbao, Binan, Laguna;

2.) PETITIONER GLADISE M. NAVARRO is also of legal age, Filipino,

legitimated descendant (daughter) of RESPONDENT CABRINE L. NAVARRO and

presently residing at Blk. 11, Lot 11, Souhtville 5, St. Joseph Village, Brgy. Timbao,

Binan, Laguna;
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3.) RESPONDENT CABRINE L. NAVARRO is of legal age, Filipino,

married to PETITIONER DESIREE M. NAVARRO and presently residing at PO Box

9801 61008, Ahmadi, Kuwait, Saudi Arabaia or # 054 Putng Bato West, Calaca,

Batangas, where he may be served with notices and other processes of the Court;

4.) PETITIONER DESIREE M. NAVARRO and RESPONDENT were

legally united in marriage on September 28, 1991 at the Metropolitan Trial Court

Compound in Manila by Rev. Errol F. McKeehan, photocopy of the Certificate of

Marriage is herewith attached and made an integral part hereof as Annex “A”;

5.) PETITIONER DESIREE M. NAVARRO and RESPONDENT during the

time of their marriage were both of legal age being 22 and 25 years of age

respectively;

6.) Out of their cohabitation, a child was born namely Gladise M. Navarro,

herein CO-PETITIONER, who was born on July 31, 1988 at Phil. General Hospital

located at Taft Ave., Manila, photocopy of her Certificate of Live Birth is herewith

attached and made integral part hereof as Annex “B”;

7.) At the time of the filing of this Petition, CO-PETITIONER GLADISE M.

NAVARRO is 22 years of age and at present is a 3 rd year dentistry student at Centro

Escolar University at Mendiola, Manila;

8.) PETITIONER DESIREE M. NAVARRO and RESPONDENT were

sweethearts since their teenage years and before RESPONDENT left for abroad as an

overseas contract worker, PETITIONER DESIREE M. NAVARRO was already

pregnant;
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9.) PETITIONER GLADISE M. NAVARRO was born out of wedlock on

July 31, 1988 before PETITIONER DESIREE M. NAVARRO & RESPONDENT got

married on September 28, 1991;

10.) After their marriage on September 28, 1991, PETITIONER DESIREE

M. NAVARRO &RESPONDENT lived together in Calaca, Batangas; after one and a

half months, RESPONDENT again left for abroad, this time in Kuwait, where he

works for ten (10) straight years, but for four (4) years they never communicated with

each other;

11.) PETITIONER DESIREE M. NAVARRO patiently took good care of

their only daughter (herein CO-PETITIONER GLADISE M. NAVARRO) providing

for her needs;

12.) PETITIONER DESIREE M. NAVARRO heard so many news about the

philandering activities and infidelity of the RESPONDENT while working abroad,

and even when he is in the Philippines, he had the temerity to date other girls;

13.) There were several instances that several women on different occasions

would suddenly appear in their house, pretending to be a co-worker of the

RESPONDENT in Kuwait, introducing herself as “Mary” whom PETITIONER

DEISREE M. NAVARRO later on came to know that her real name was Rosie

Pangan, who was impreganated by the RESPONDENT while in Kuwait and who just

went home to the Philippines to give birth to their illegitimate child;

14.) The following month, another woman went in their house, introduced

herself as Sylvia Salvador and represented that RESPONDENT instructed her to look

for PETITIONER DESIREE M. NAVARRO;


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15.) PETITIONER DESIREE M. NAVARRO confronted the Sylvia Salvador

and told her “dalawa na kayong pumunta dito”;

16.) All the other women of the RESPONDET had done nothing but to create

trouble in the private lives of the PETITIONERS;

17.) Until PETITIONER DESIREE M. NAVARRO discovered that whenever

RESPONDENT would return to the Philippines for a vacation, he would have a girl

impregnated, and in fact, he begot (5) children with different girls;

18.) And the latest among them is a certain Evangeline Navarro whom

RESPONDENT is living-in at present in Kuwait; Evageline Navarro even had the

guts to use the surname “Navarro” used in her personal and official records like the

Philippine Passport despite the fact that the use of the surname “Navarro” is illegal;

they begot a child and named him Junior Navarro;

19.) All these illicit activities of the RESPONDENT had caused a severe

dissipation in the monthly support being given by the RESPONDENT to the herein

PETITIONERS; the amount of monthly support started to wane starting this year;

20.) PETITIONERS are in dire need of financial support specially CO-

PETITIONER GLADIES M. NAVARRO who is already in the last two (2) years of

her dentistry course;

21.) If RESPONDENT would not give her support, she might be forced to

stop schooling, thus, ruining a bright future for an intelligent daughter, who, because

of the philandering ways of the father, will shatter a daughter’s dream of becoming a

dentist;
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22.) On the part of PETITIONER DESIREE M. NAVARRO, she could no

longer make both ends meet; she is just an ordinary “seller in the public market”

whose income is very unstable; she had suffered so much not only emotionally but

also physically in trying to send a loving daughter to school;

23.) PETITIONERS herein desire that a monthly support be given to them by

the RESPONDENT in the total amount of One Hundred Thousand (P 100,000.00)

Pesos considering that the latter’s monthly income in Kuwait is not less than Three

Hundred Thousand (P 300,000.00) Pesos;

24.) PETITIONER demanded that the y be given the above amount as

monthly support, RESPONDENT however did not heed their demand, photocopy of

the demand letter is hereto attached as Annex “C”;

25.) As a result of RESPONDENT’S unjustified refusal to heed

PETITIONER’S just & valid demands, the latter suffered sleepless nights &

besmirched reputation for which they should be indemnified in the amount of Fifty

Thousand (P 50,000.00) Pesos as and by way of moral damages;

26.) The reckless, abusive & oppressive manner by which RESPONDENT

violated & disregarded PETITIONERS’ rights likewise warranted the payment of

exemplary damages in the amount of Fifty Thousand (P 50,000.00) Pesos;

27.) Thus, PETITIONERS were constrained to hire the services of the

undersigned LAW OFFICES because of RESPONDENT’S unjustified failure and

refusal to heed their demand for support and committed themselves to pay the

undersigned LAW OFFICES the amount of Fifty Thousand (P 50,000.00) Pesos plus
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an Appearance Fee of Three Thousand (P 3,000.00) Pesos for each and every court

appearance.

VERIFIED APPLICATION FOR SUPPORT PENDENTE LITE

PETITIONERS hereby replead and reproduce the forgoing allegations and

hereby state further that -

28.) RESPONDENT, at present, is a cementing supervisor of Natesco, a firm

situated at Kuwait, Saudi Arabia and is receiving a monthly compensation of not less

than Three Hundred Thousand (P 300,000.00) Pesos;

29.) As previously adverted to above, PETITIONER DESIREE M.

NAVARRO is a mere seller in the public market while PETITIONER GLADISE M.

NAVARRO is still a 3rd year dentistry student at Centro Escolar University;

30.) Legal support between spouses arises from the fact of marriage. (Pelayo

vs. Lauron, 12 Phil 453) Support for education shall continue up to the completion

of one’s course, even beyond the age of majority. (Javier vs. Lucero, 50 OG 4845)

PRAYER

WHEREFORE, premises considered, it is respectfully prayed that after due

hearing:

1.) An order for support pendente lite be issued requiring the RESPONDENT

to give support to the PETITIONERS in an amount not less than One Hundred
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Thousand (P 100,000.00) Pesos to be paid on or before every fifth (5 th) day of the

month at the residence of the PETITIONERS;

2.) After trial on the merits, another order be issued ordering the

RESPONDENT to give PETITIONERS a monthly support of One Hundred

Thousand (P 100,000.00) Pesos to be paid on or before every fifth (5 th) day of the

month at the residence of the PETITIONERS;

3.) Ordering the RESPONDENT to pay PETITIONERS the sum of:

a.) Fifty Thousand (P 50,000.00) Pesos as moral damages;

b.) Fifty Thousand (P 50,000.00) as exemplary damages;

c.) Fifty Thousand (P 50,000.00) Pesos as and for attorney’s fees.

4.) Costs of suit.

Other relief just and equitable under premises are similarly prayed for.

Pasig City, Metro Manila for Binan, Laguna, June 21, 2010.

MACABABBAD LAW OFFICE


RM. 1526 15th F, CITY & LAND MEGAPLAZA
ADB AVE. COR. GARNET RD., ORTIGAS CENTER
PASIG CITY, METRO MANILA

BY

ATTY. LIONELL M. MACABABBAD


MCLE COMPLIANCE # III-0012459/04-15-10
PTR # 7817884/01-04-10/BATANGAS
IBP # 804181/01-04-10BATANGAS
ROLL # 38870
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VERIFICATION/CERTIFICATION

WE, DEISREE M. NAVARRO & GLADISE M. NNAVARO, both of legal


age, and presently residing at Blk. 11, Lot 11, Southville 5, Saint Joseph Village,
Brgy. Timbao, Binan, Laguna, after having been duly sworn in accordance with law,
hereby, depose and say that:

1. We are the Petitioners in the above entitled case;

2. We have read the allegations contained in the petition and hereby state that
the same are true and correct to the best of my knowledge & belief.

3.) We have not commenced any other action or proceeding involving the
same issues in the Supreme Court, the Court of Appeals, or any other
tribunal or agency; To the best of our knowledge, no such action or
proceeding is pending in the Supreme Court, the Court of Appeals, or any
other tribunal or agency; & if we should thereafter learn that a similar
action or proceeding has been filed or is pending in the Supreme Court,
the Court of Appeals, or any other tribunal or agency, we shall report that
fact within five (5) days therefrom to this Honorable Court.

DESIREE M. NAVARRO GLADISE M. NAVARRO

SUBSCRIBED AND SWORN to before me this … day of ………………. ,


affiant exhibiting to me their CTC # …………….., issued at …………….. on
………. & CTC …………… issued at ………………. on ……………….

Doc. No……
Page No. …..
Book No……
Series of 2010.

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