REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT OF PARANAQUE

NATIONAL CAPITAL JUDICIAL REGION
BRANCH ____

__________________________________,
Petitioner,

- versus - CIVIL CASE NO. _____________

FOR: JUDICIAL SEPARATION
OF PROPERTY

__________________________________,
Respondent.
xx- - - - - - - - - - - - - - - - - - - - - -xx

PETITION

NOW COMES the Petitioner, through her undersigned

counsel, and to this Honorable Court respectfully states that:

1. Petitioner is of legal age, Filipino, and with postal

address at _______________________________.

2. Respondent on the other hand is likewise of legal

age, Filipino and with postal address at
____________________________ where summons and other
processes of this Honorable Court may be served upon him.

3. Petitioner and Respondent were legally married in

Quezon City on 26 February 2002 as evidenced by a copy of
their Certificate of Marriage attached hereto as Annex “A” and
made an integral part hereof.

4. _______ children have resulted from their union.

5. Since the time that they were married and up to

now, Petitioner and Respondent have acquired the following
properties:

Personal Properties:
1. _______________
2. _______________
3. _______________
 Real Properties:
1. _______________
2. _______________
3. _______________

6. Due to irreconcilable differences, Petitioner and

Respondent have been living apart, since __________ and up to
the present, and reconciliation is highly improbable thus
making judicial separation of their properties proper and
warranted in accordance with Article 135 (6) of the Family
Code.

7. While Petitioner has no creditors nor financial

obligations to third parties, she is unaware if the Respondent
has creditors or financial obligations to third persons, and has
no control over his finances and/or business dealings thus
further justifying judicial separation of their properties in
order to Petitioner may be shielded from liability for any and
all financial obligations that have been incurred or may be
incurred by the Respondent to third persons which have never
benefited herein Petitioner.

8. Petitioner is thus entitled to a judicial separation of

property as a consequence of which the property relations
between her and the Respondent should thereafter be
governed by complete separation of property in accordance
with Article 145 of the Family Code and, as a further
consequence thereof, all undisclosed debts which were and
may hereinafter be contracted or incurred by either party
shall be borne exclusively by the contracting party and shall
hold the other party free and harmless of any undisclosed
liabilities.

9. Petitioner thus submits that their above-

enumerated and described properties should be divided in the
following manner:

1. __________________________________________

2. __________________________________________

3. ___________________________________________
 PRAYER

WHEREFORE, premises considered, it is respectfully

prayed of this Honorable Court that - after due notice and
hearing - judgment be rendered in favor of herein Petitioner
dissolving the absolute community of property of the parties
and decreeing that they shall be governed by a regime of
separation of property in accordance with Articles 144 and
145 of the Family Code and their common properties be
divided and apportioned to each of them in the manner
described above.

Petitioner prays for other just and equitable measures of

relief.

____________ City for _____________ City. ___________2016.

_________________________________
Counsel for the Petitioner
Lawyers’ Roll No. _____________
PTR No. ________________________
IBP No. _________________________
MCLE Comp. No. ______________________
_________________________________
_________________________________
Tel. No.: ___________ e-mail: ___________________
Republic of the Philippines)
____________________________) s.s.

VERIFICATION AND
CERTIFICATION OF NON-FORUM SHOPPING

I, _____________________________, after having duly sworn

in accordance with law, depose and say that I am the
Petitioner in the instant petition and in such capacity I have
caused the preparation and filing thereof.

I have read the contents of the petition and I affirm that

they are all true and correct based on my personal knowledge
and/or available and authentic documents.

I finally certify that I have not commenced any similar

action or proceeding before the Supreme Court, Court of
Appeals nor any judicial or quasi-judicial body and further
undertake to inform the Honorable Court of any similar
action/proceeding that may come to knowledge within five (5)
days from receipt of such knowledge.

IN WITNESS WHEREOF, I sign this document this ___

day of __________________ 2016 in ___________________.

_________________________________
Petitioner

SUBSCRIBED AND SWORN TO before me, a Notary

Public for and in __________________, this ____ day of
___________________ 2016, _____________________ exhibiting to
me her document of identity: _______________________________
issued on ___________________ in _____________________.

Notary Public

Doc. No. ____

Page No. ____
Book No. ____
Series of 2016.