Republic of the Philippines
Fourth Judicial Region
REGIONAL TRIAL COURT
Calamba City
Branch ___
Goldie G. Er
Petitioner,
Civil Case No. _____
- versus - For: Declaration of
Nullity of Marriage
Phil Ander Er
Respondent.
X --------------------------------------------- X
PETITION
PETITIONER, by the undersigned counsel and unto this
Honorable Court, respectfully states that:
1. Petitioner is of legal age, Filipino, married to respondent and
a resident of 213 Phase 1 Olivarez Homes, Brgy. Tulo,
Calamba City. For the purposes of this petition, she may be
served with summons, orders and other legal processes of
this Honorable Court at the above-mentioned address;
2. Petitioner and respondent are husband and wife, having
been legally married on February 29, 2016 at St. John the
Baptist Church in Calamba City. A copy of their marriage
certificate is herein attached as Annex A;
3. During their marriage, the petitioner and respondent have
amassed several real and personal properties that they
purchased using their absolute community funds as
evidenced by various certificate of titles herein attached as
Annex B-1, Annex B-2, Annex B-3, Annex B-4, Annex B-5,
Annex B-6, Annex B-7, Annex B-8, Annex B-9 and Annex B-
10;
4. Respondent held various personal and joint bank accounts
amounting to P5,987,246,892.10 as of December 31, 2019
with the petitioner as evidenced by various bank accounts
herein attached as Annex C-1, Annex C-2, Annex C-3,
Annex C-4, and Annex C-5;
5. Four (4) years after their marriage, petitioner left the conjugal
dwelling after learning that the respondent was previously
married to Misty Ress in the United States of America as
evidenced by respondent’s marriage certificate herein
attached as Annex C;
WHEREFORE, petitioner respectfully prays that, after trial,
judgement be rendered in her favor by:
1. declaring that petitioner and respondent’s marriage is null
and void for being bigamous marriage under Art. 35 (4) of
the Family Code;
2. ordering the dissolution and partition of the absolute
community of property existing between them.
All other just and equitable reliefs are also prayed for.
Calamba City; May 15, 2020.
ATTY. EFREN ELVIN PERIA
Counsel for the Petitioner
Ramilo Compound, Sitio Fajardo II, Brgy. Lecheria, Calamba City
4027
Roll No. 71793
IBP OR No. 71793, January 2020, Calamba City
PTR OR No. 71793, January 2020, Calamba City
VERIFICATION
Republic of the Philippines )
City of Calamba ) s.s.
Goldie G. Er, after having been duly sworn in accordance with
law, deposes and states that:
1. The allegations in the pleading are true and correct based on
her personal knowledge and authentic documents;
2. The pleading is not filed to harass, cause unnecessary delay, or
needlessly increase the cost of litigation; and
3. The factual allegations therein have evidentiary support.
Goldie G. Er
Petitioner
CERTIFICATION AGAINST FORUM SHOPPING
Republic of the Philippines )
City of Calamba ) s.s.
Goldie G. Er, after having been duly sworn to in accordance
with law deposes and states that:
1. She is the petitioner in the herein case;
2. She certifies that she has not commenced any action or field
any claim involving the same issues before any other court,
tribunal, or quasi-judicial agency;
3. To the best of her knowledge, there is no such pending action
or claim; and
4. If she should learn that a similar action or claim has been filed
or is pending, she shall report such fact within five (5) days from
the discovery to this Honorable Court.
Goldie G. Er
Petitioner
