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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT


7th Judicial Region
Branch 9
Cebu City
a
Plaintinff,
-versus-

CIVIL CASE NO._______

b,
Defendant.
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COMPLAINT FOR SUPPORT, WITH ALIMONY PENDENTE LITE
1. That Plaintiff a is of legal age and a resident of Don Pedro Cui Street,
Cebu City and defendant b is likewise of legal age and an resident of Sta.
Mesa, Manila;
2. That defendant and plaintiff are husband and wife having been legally
married on June 7, 2000 and before the Parish Priest of Malate Catholic
Church, Manila, copy of their marriage certificate being attached to this
complaint as Annex A;
3. That out of said marriage were born two legitimate children, namely c and
d, Both one (1) year of age now;
4. That on or about 7th of February 2001, defendant without justifiable cause
of reason, abandoned the conjugal home, leaving the two aforementioned
minor children with plaintiff, and, since then, defendant had failed and
refuse, and still fails and refuses, to provide for the support and
maintenance of plaintiff and the two children.
5. That Plaintiff is totally without any source of income, while defendant is a
businessman and at the same time the Chief Executive officer of Lee
Company (Phils.), earning an average Monthly Income of EIGHT
HUNDRED THOUSAND PESOS (Php800,000.00), more of less;

6. That, considering the present cost of living, plaintiff and her two minor
children need a monthly allowance of, of least, FIFTY THOUSAND
PESOS (P50,000.00) for their maintenance and support;
7. That, in support of Plaintiffs claim or alimony pendent elite, the following
affidavits, depositions or other authentic documents are attached to this
complaint;
(Specification & brief description of corresponding annexes.)

WHEREFORE, plaintiff prays for judgment:


1. Ordering defendant to give plaintiff a monthly allowance of FIFTY
THOUSAND PESOS (P50,000.00), to be paid on or before the 5 th of every
month, as alimony pendent elite;
2. After trial, ordering that said monthly support be made permanent;
3. Ordering defendant to reimburse plaintiff for attorneys fees in the amount
of THIRTY FIVE THOUSAND PESOS (P35,000.00); and
4. Cost and other equitable remedies).
Most respectfully submitted.
Cebu City, Philippines__________________.

Name of Counsel,
(Place, date and signature)
IBP No.______________
PTR No.______________
MCLE No.____________
Roll No.______________

(VERIFICATION AND CERTIFICATION of Plaintiff)


(Notice and Proof of Service)

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