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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT


REGION XI
BRANCH____
DIGOS CITY

LIEZL GARCIA LOPEZ, CIVIL CASE NO. 1234


Petitioner

-versus-

RICARDO TAN LOPEZ


Respondent,
x-------------------------------/

PETITION FOR LEGAL SEPARATION

1. Petitioner Liezl Garcia Lopez and respondent Ricardo Tan Lopez met
each other sometime on February 14, 1980 at one their common
friend’s birthday party. Their dating all started and went well and
finally after two years of being in a relationship they decided to get
married last September 25, 1982 at St. Paul’s Church, Matina, Davao
City. A copy of their marriage certificate hereto attached as Annex
“A” and made an integral part of this petition;
2. After their marriage, the couple decided to settle at Insular Village,
Davao City where they built their family home;
3. The union produced three (3) children, namely: Ryan G. Lopez , born
on February 16, 1984, Jericho G. Lopez, born on April 22, 1987 and
Emeglen L. Villanel, born on December 7, 1988. Copies of their
Certificates of Live Birth are hereto attached as Annexes “B”, “C”
and “D” respectively, and made an integral part of this petition;
4. Undeniably, the couple’s marriage was harmonious and the
respondent husband was a good provider to the family. There were
times when they had minor arguments but they can easily settle those
arguments. They both manifested display of intimacy and giving of
trust and respect each other. Respondent husband always made sure
that the welfare of the respondent and their children was his priority
over and above anything and anybody else;
5. Petitioner thought and hoped that the harmonious family they started
and built will continue to prosper but it started to fade at the middle of
their stages of their marriage, respondent was engrossed in gambling
all of his income as a surgeon doctor where not enough to provide for
his gambling and he failed to support the family. Respondent was
slowly turning into an irresponsible father and a husband.
6. Unfortunately, the gambling addiction did not stop and he eventually
engaged in drug addiction that lead him to stop working at his clinic
located at Davao Doctor’s Hotel, this time respondent got worst that
he went home late and was under drugs;
7. The worst transformation of respondent husband continued and he
refused to stop his vices this will lead into their fights and eventually
respondent inflicted physical violence to petitioner;
8. Sometime in January 5, 2016 the physical violence committed by
respondent due to their fights lead the petitioner to blotter the incident.
A copy of the Blotter report is hereto attached as Annex “E” and
made an integral part of this petition;
9. On January 6, 2016, respondent husband then left the conjugal
dwelling and has not returned ever since. When the petitioner went to
the clinic of respondent he can never be found. Moreover, he was not
able to fulfill his obligations to his family especially to his children
who were all enrolled at Ateneo de Davao University. From then on,
there is a complete cessation of marital relations between petitioner
and respondent, both personal and property, as well as parental
relations with their children as respondent no longer gave them any
support, may it be emotional or financial;
10. Petitioner can and will no longer tolerate respondent’s continued
blatant transgression of his marital vows because the confluence of his
irresponsible and unwarranted acts, amounting to failure on his part to
perform his duty to live with the petitioner, duty to observe mutual
love help and support is just too much for her to handle. Hence, the
foregoing considered, this Petition for Legal Separation on the
following grounds: a. Repeated physical violence or grossly abusive
conduct directed against the petitioner; b. Drug Addiction; and c.
Abandonment of petitioner by respondent without justifiable cause;
11. In filing this petition, petitioner was constrained to engage the
services of a counsel for an acceptance fee of Php 50,000.00 and per
appearance fee of Php 3,000.00, and will incur in litigation expenses
in the sum of Php 80,000.00.

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