Professional Documents
Culture Documents
Republic of The Philippines
Republic of The Philippines
Department of Justice
Office of the Provincial Prosecutor
Misamis Oriental
RENATO MARQUEZ
Accused
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THE PARTIES
THE CHARGE
[3.b] That I replied that I did not have any contraband and that my
husband, Leo Tan, was in the poblacion at that time. The men
ordered me to open up otherwise they will shoot our house.
[3.c] Afraid, I opened the window shutter when, suddenly, a man
armed with gun, whom I recognized as Renato Marquez jumped
inside. I was able to recognize Renato Marquez as the light was
bright. Renato held me by the nape and pushed me towards the
door and at gunpoint ordered me to open the same. I was not able
to shout as I was caught by surprise.
[3.e] That after Renato Marquez ransacked our store and took
merchandise therefrom, he raped me at gunpoint. After five
minutes, he took me upstairs and tied both of my arms and made
me face down on the floor together with my children.
[3.f] After the men had left and we did not hear any noise anymore,
Anna, my daughter, was able to untie me by cutting the rope.
[3.g] That aside from the money taken by the accused, they also got
the following: radio worth P125.00; radio-phone worth P135.00; a
ten-battery flashlight valued at P10.00, an P85.00 wrist watch,
necklace, worth P6,000.00.
ANNEXES
LETICIA TAN
Affiant
Q1: Do you swear to tell the truth, the whole truth and nothing but
the truth?
A1: Yes Sir.
Q2: Will you please state your state your name and other personal
circumstance?
A2: I am Leticia Tan, married, a resident of Barangay Patag,
Cagayan de Oro City.
Q6: After Renato Marquez had taken the eight hundred twenty
pesos from your pillow, anything more happened?
A6: Because I could not do anything, 'kinuha ang aking
pagkababae', sir.
Q9: Did you voluntarily answered all the questions asked in this
affidavit?
A9: Yes, sir.
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LETICIA TAN
Affiant
MARTA SANTOS,
Petitioner
-versus- Civil Case No. 2022-01-05
For: Judicial Declaration
of Nullity of Marriage
JULIO SANTOS
Respondent
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COMPLAINT
THE PARTIES
Art. 36. A marriage contracted by any party who, at the time of the
celebration, was psychologically incapacitated to comply with the
essential marital obligations of marriage, shall likewise be void and
even if such incapacity becomes manifest only after its
solemnization.
Art. 68. The husband and wife are obliged to live together, observe
mutual love, respect and fidelity, and render mutual help and
support.
Art. 72. When one of the spouses neglects his or her duties to the
conjugal union or commits acts, which tend to bring danger,
dishonor or injury to the other or the Family, the aggrieved party
may apply to the court for relief.
[4] Petitioner is a young lady of 25 years old during that time who
works under the Human Resources Department of National
Panasonic. Petitioner graduated Bachelor of Psychology in Xavier
Universit. Respondent, on the other hand, is a Production Engineer
under the same company.
[6] The classic love affair between Mr. Julio Santos and Ms. Marta
Santos started when the latter was introduced to the petitioner
through her cousin Pia. She and Julio were workmates in National
Panasonic. What started as a simple acquaintance was followed by
an intense courtship; Julio was immediately attracted to her that
soon enough he was deeply engrossed with her. Julio would often
bring Marta to and fro in her place of work; he visited her in their
house almost on a daily basis. These adorable actuations of Julio
eventually led to a romantic affair between him and the
respondent.
[7] They after then decided that they will get married because they
have both found the “right one” for them. Both families agreed that
since Julio and Marta are gainfully employed, they should now tie
the knot. Most members of their respective families attended the
marital ceremony
Attached as “Annex A” is the Certificate of Marriage.
The first stages of their married life were full of happiness and
excitement. She and Julio lived with her family after the wedding
and her family was cordial towards him.
[11] Then one faithful day came when Julio left her and their two
children. She later on found out that the reason why he left was
because of a woman named Roline. She also found out that the said
woman was the one her husband was always talking over the
phone.
[14] Nonetheless, Marta moved on with her life. Julio, on the other
hand, continued living with Roline and begot two children with her.
[15] Julio even failed to support them, as he did not even give her
allowance for their expenses and in support of their children’s
studies. Marta, then, has no choice but to ask help from her parents
and siblings for her meager salary in Land Bank cannot support the
studies of her two children, plus with the expenses she has to pay
for their house and other loans. She can, however, see that his
second family is well-provided by Julio as his two children with
Roline even studies in a private school. Despite the said turn of
events in their lives, Marta was able to move on and work in order
to support their children, which obviously were also forgotten by
Julio, as he is deeply engrossed to his new family.
PRAYER
Plaintiff likewise prays for such other and further relief or reliefs as
this Honorable Court may deem just and equitable in the premises.
ANNEXES
MARTA SANTOS
Affiant
(c) Marta and her children did not receive any financial support
from Julio while his second family is well-provided by Julio as his
two children with Roline.
Q1: Do you swear to tell the truth, the whole truth and nothing but
the truth?
A1: Yes Atty.
Q2: Will you please state your name and other personal
circumstance?
A2: I am Marta Santos, of legal age, married, and a resident of
Barangay Patag, Cagayan de Oro City.
Q7: Are you aware that this affidavit is under oath which means
that you may be prosecuted for perjury if it turns out that you lied
in any of the answers you have given in response to the questions
propounded to you?
A7: Yes, Atty.
Q17: Is there anything else that you would like to add or amend
from your statements?
A17: Nothing more, Atty.
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MARTA SANTOS
Affiant