Pre Trial Brief Petition For Declaration of Nullity of Marriage
Pre Trial Brief Petition For Declaration of Nullity of Marriage
MARIAN RIVERA
Petitioner,
DINGDONG DANTES,
Respondent.
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PRE-TRIAL BRIEF
3. that the root cause of such illness is traced from their respective childhood;
5. that such illness existed before, at the time of the marriage and during the
marriage.
8. that respondent failed to give love, emotional support and fidelity to the
marriage;
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9. that respondent denies all the allegations of the Petitioner.
2. The fact of marriage, parties having been married on December 02, 2002 ;
5. Their de-facto separation and the absence of cohabitation between the spouses.
2. that the said disorder of the respondent is grave, serious and incurable.
3. That the respondent and the petitioner are both psychologically incapacitated to
comply with the requisites of marriage.
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Whether or not respondent is psychologically incapacitated to comply with the
essential requisites of marriage which is a valid ground under Art. 36 and 68 of
the New Family Code to declare the marriage a nullity.
a. Considering the relatively simple issues presented, Respondent does not intend
to avail of discovery at this time.
Petitioner will be testifying on the allegations in the Petition and will present
documentary evidence. The Clinical Psychologist who will testify on the
psychological evaluation done on both petitioner and respondent.
Petitioner Marian Rivera, reserves the right to present any and all
documentary evidence , which shall become relevant to rebut respondent’s
witnesses ’, if necessary.
The petitioner needs at least five (5) trial dates to present its case to be
agreed upon during the Pre-trial Conference.
Copy furnished:
Pursuant to the Provision of Rule 13, Section 11 of the 1997 Rules in Civil
Procedure as Amended, undersigned submits this Explanation that the service of
this Pre- Trial was to Office of the Solicitor General by Registered Mail instead of
personal serve in view of lack of manpower.
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