Republic of the

Philippines
REGIONAL TRIAL
COURT
National Capital
Region Branch Quezon
City

Gabby Convulción Civil Case No. 27-123011

Petitioner,
- versus -
Sharon Cometa
Respondent.
x---------------------x

TRIAL MEMORANDUM

Plaintiff, by counsel, respectfully states that:

Preftory Statement
“Neither man nor woman is perfect or complete without the other.
Thus, no marriage or family, no ward or stake is likely to reach its full
potential until husbands and wives, mothers and fathers, men and women
work together in unity of purpose, respecting and relying upon each other's
strengths.”
-Sheri L. Dew

Statement of the Facts

1. That Gabby Convulción and Sharon Cometa were schoolmates at the
New Era University where they both took up Law, where he courted
Sharon and became sweethearts thereafter.
2. That Gabby introduced Sharon to his family, and Sharon’s attitude
towards them was not welcoming, and that he tried to break up with her
but continued to see each other “on a friendly basis.”
3. That Sharon later on informed Gabby that she is pregnant with his child,
and Married at the Metropolitan Trial Court of Manila by its Presiding
Judge.
4. That after the marriage, Sharon remained aloof, and refused to have sex
with Gabby. Although Sharon tells that she is pregnant, no symptoms of
pregnancy is visible.
5. That Gabby confronted her about her possible miscarriage; and Sharon
shouted “Putang ina nyo, wag kayo makialam” at Gabby’s mother.
6. That in order to protect their interests, Gabby filed a petition for
declaration if nullity of marriage with the Regional Trial Court of Manila.
Despite summons, Sharon did not participate in the proceedings..
7. The OSG appealed, and the CA reversed the decision of the RTC. It held
that Gabby failed to establish, above all, that Sharon’s alleged Narcissistic
Personality Disorder was in fact, the psychological incapacity contemplated
by law and that it was permanent and incurable.
8. That Gabby files this petition before the Court to have the Court of
Appeals decision reversed.
Given the foregoing facts and circumstances, the following
issues are presented
Issue

for
discussion:
 1. WHETHER OR NOT ALLEGED PERSONALITY DISORDER OF
THE RESPONDENT IS A GROUND FOR PSYCHOLOGICAL
INCAPACITY?

Arguments

This is a verified petition IN ORDER TO REVERSE the Court of

Appeals decision and the Regional Trial Court be reinstated, filed by
Gabby Convulción
Gabby exhausted ways to keep his wife, and his family closer,
but Sharon’s attitude towards his very own family is not acceptable for
the establishment of a harmonious family life. Sharon never changed her
attitude towards her family for a petty reason that she is simply seems to
like to play with Gabby’s emotions and weaknesses (alleging that Gabby
has a relationship with another woman.) This evasive thought clouds the
mind of Sharon, making her periodically do what is adverse of the
family relationship.
Sharon’s shouting of “Putang ina nyo, wag kayo makialam” after
Gabby asked about a possible miscarriage, is another repercussion of her
adverse attitude which is a huge possibility that is an effect of a
Narcissistic Personality Disorder. It shows that Sharon does not have any
feeling or care for other’s feelings, the absence of affection and love,
mirrored by her refusal to have sexual intercourse with his husband
giving her a pattern of unexplained and remoseful feelings.
This argument not only supports, but intensifies the claim that
Sharon has a Narcissistic Personality Disorder, affirming the earlier
decision on the RTC.

WHEREFORE, the instant petition is AFFIRMED. The Decision of the

RTC is likewise AFFIRMED.

SO ORDERED.
 Quezon City, February 10, 2018.

Arch John Camps

Representative for
Petitioner
Address:
IBP No:
PTR No:
Roll No:
MCLE
No:
Copy furnished:
ATTY Jonathan
Landis
Counsel for
Defendant

EXPLANATION
In view of time and manpower restrictions, the above Memorandum
was served via registered mail as personal service could not be availed of
without causing undue hardship to petitioner.

Arch John Camps

Counsel for Defendant