REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL REGION

REGIONAL TRIAL COURT
PASIG CITY
BRANCH NO. 158

ROMEO RIVERA, petitioner

-VERSUS- CIVIL CASE NO. 2187-A

FOR: DECLARATION OF NULLITY
OF MARRIAGE DUE TO

PSYCHOLOGICAL INCAPACITY
JULIET JOAQUIN, respondent

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PETITION

I, ROMEO RIVERA, of legal age, Filipino, married to defendant, and a

resident of 16 Rosewood St. Greenwoods Executive Village, Pasig City, depose
and state:

1.Petitioner is a graduate of Bachelor of Science in Accountancy from

University of Santo Tomas. He passed the Licensure Exam for Certified Public
Accountants.

2. The respondent Juliet Joaquin is 36 years old, and a resident of #1 Charles

St., Kingsville Subd., Antipolo, Rizal, where she may be served with summons
for the instant case.

3. Petitioner has been employed as a Senior Audit Associate at SGV & Co.

4. Petitioner and respondent met in 1996. They maintained a relationship and

eventually married in 1999.
Attached is Exhibit A Marriage Certificate.

5. Petitioner and respondent had four children.

6. During their time of cohabitation starting from 1999, respondent was a
housewife so she could focus on their children.

7. Respondent loved to play mah-jong, and played at least twice a week, and
sometimes brought the children to where she played mah-jong. Respondent
also loved to go out and party on weekends, almost always coming home the
mornings after, and sometimes bringing her male friends to the conjugal home.

8. Sometime in 2008, petitioner caught wife in a hotel room with another man.

9. Respondent left the conjugal home. It was agreed by both parties that
respondent would have custody of the children on weekends, and petitioner
on the weekdays. But after a month, she no longer visited the children.

10. The petitioner has engaged the services of the undersigned counsels, TK
LAW (Tolentino & Kadjim) for the preparation and filing of the petition.

11. The petitioner had engaged the services of Dr. Jean Paul Gueco, Clinical
Psychologist, for the determination of psychological evaluation of both parties,
who will be presented as an expert witness in support of the instant petition.

Attached is Annex B is a copy of the Curriculum Vitae of Dr. Gueco, Clinical

Psychologist.

12. Based on the results of the psychological tests and interview on the parties
and corroborator as well as based on the background data gathered and
marital history of the parties, the findings of Dr. Gueco are reproduced in the
succeeding paragraphs herein below, culled from the Report of Dr. Gueco,
attached as Annex C hereof, to wit:

The client (Respondent) is suffering from Narcissistic Personality Disorder.

This is characterized by a pervasive pattern of grandiosity, need for admiration
and lack of empathy as indicated by the following: she has as a grandiose sense
of self-importance, she has a sense of entitlement, she is interpersonally
exploitative where he takes advantage of others to achieve his own ends, she
lacks empathy where he is unwilling to recognize or identify with the feelings
of his wife and he showed arrogant behaviors.
Narcissistic personality disorder crosses the border of healthy confidence into
thinking so highly of yourself that you put yourself on a pedestal and value
yourself more than you value others..

13. The diagnosed psychological incapacities of both the petitioner and the
respondent prevent them from mutually performing their marital duties to
each other. In support of this, Dr. Gueco states:
Due to the fact that Ms. Juliet Joaquin is suffering from Narcissistic Personality
Disorder, this all to show that she cannot fulfill her marital obligations. All
symptoms are present in this case and according to the entire test that I have
conducted, she is no longer capable to perform his duties as wife.

14. Dr. Gueco thus recommends that the marriage between the parties be
declared null and void based on the established psychological incapacitation of
both the petitioner and the respondent.

PRAYER

WHEREFORE, premises considered, it is respectfully prayed that the

marriage of the parties be declared null and void from the beginning under
Article 36 of the Family Code.

Petitioner also prays for other reliefs as may be deemed just and
equitable in the premises.

IN WITNESS WHEREOF, I have hereunto set my hand this 20th day

of May, 2017 at Manila, Philippines.

______________________
ROMEO RIVERA
Petitioner

TK LAW (Tolentino & Kadjim) LAW OFFICES

Counsel for the Petitioner
1152, 4th flr., DAP Bldg.,
San Miguel Ave., Pasig City

VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

I, ______ROMEO RIVERA__________, of legal age, after having been duly sworn in

accordance with law, depose and state that:
1. I am a petitioner in the above-stated case;
2. I caused the preparation of the foregoing complaint;
3. I have read the contents thereof and the facts stated therein are true and
correct of my personal knowledge and/or on the basis of copies of documents
and records in my possession;
4. I 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;
5. To the best of my knowledge and belief, no such action or proceeding is
pending in the Supreme Court, the Court of Appeals, or any other tribunal or
agency;
6. If I should thereafter learn that a similar action or proceeding has been filed
or is pending before the Supreme Court, the Court of Appeals, or any other
tribunal or agency, I undertake to report that fact within five (5) days
therefrom to this Honorable Court.

___________________________
ROMEO RIVERA
Affiant

SUBSCRIBED AND SWORN to before me this ___ day of __________ 200_

at _________________ affiant exhibiting to me his Community Tax Certificate
No.____________________ issued on ________________ 200_ at ______________ City.

Doc. No. ;
Page No. ;
Book No. ;
Series of 200_.

ATTY. ANNESIR KADJIM