REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

11th Judicial Region
Branch 6
Davao City

ELLEN G. ADARNA
Plaintinff,
CIVIL CASE NO._______
-versus- FOR: COMPLAINT FOR
SUPPORT WITH
APPLICATION FOR
ALIMONY PENDENTE
JOHN LLOYD E. CRUZ, LITE
Defendant.
X--------------------------X

COMPLAINT
FOR SUPPORT WITH “ALIMONY PENDENTE LITE”

Plaintiff, by counsel respectfully alleges:

THE PARTIES

1. That Plaintiff, is of legal age, Filipino citizen, married,

with residence and postal address at Lot 6, Phase 8-C, Kailash St.,
Deca Homes, Mintal, Davao City;

2. That Defendant is of legal age, Filipino citizen, married, with

residence 2nd Floor, Lucita Bldg., P. Sobrecarey St., Cor. Lapu-Lapu,
Davao City, where he may be served with summons and other court
processes;

STATEMENT OF RELEVANT FACTS

3. That out of said marriage were born two legitimate

children, namely Carlo Rossi and Novellino, both surnamed Cruz,
who are now fifteen (15) and seventeen (17) years old, respectively.
4. That on or about 14th of February 2016, 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
Legal Officer of Freewill Resources Corporation (FRC), earning an
average Monthly Income of SEVENTY-EIGHT THOUSAND AND
SEVEN HUNDRED EIGHTY-EIGHT PESOS (Php78,788.00), 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 Plaintiff’s claim or alimony pendente

lite, the following affidavits, depositions or other authentic
documents are attached to this complaint as ANNEX “A”.

PRAYER

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 15th 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 attorney’s fees in

the amount of THIRTY-FIVE THOUSAND PESOS (P35,000.00);
and

Other reliefs just and equitable under the circumstances are

likewise prayed for.

Most respectfully submitted.

Davao City, Philippines, February 14, 2020.

SANTOALLA and Associates Law Offices

Counsel for the Petitioner
Doors 5 & 6, Tropicana Building,
J.P. Laurel Avenue, Lanang, Davao City
Tel. Nos.: (082) 282-3662
thesantoalla@associateslaw.com

By:
 ATTY. STEPHANIE M. SANTOALLA
IBP NO. 071717, 12/12/19, Davao City
PTR NO. 071717, 12/12/19, Davao City
ROLL ATTORNEY NO. 11077
MCLE Comp. No. IV-0004785, 3/2/19
Doors 5 & 6, Tropicana Building,
J.P. Laurel Avenue, Lanang, Davao City
Tel. Nos.: (082) 282-3662
smsantoalla@associateslaw.com

COPY FURNISHED: (By Personal Service)

JOHN LLYOD E. CRUZ

2nd Floor, Lucita Bldg., P. Sobrecarey St.,
Cor. Lapu-Lapu, Davao City

ATTY. MELINDA A. CHAVEZ

Doors 6, Tropicana Building, J.P. Laurel
Avenue, Lanang, Davao City

VERIFICATION AND CERTIFICATION OF NON

FORUM SHOPPING
 I, ELLEN MERRIAM G. ADARNA, of legal age, after
having been duly sworn in accordance with law, depose and
state that:

1. I am a plaintiff 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.

ELLEN MERRIAM G. ADARNA

Affiant

SUBSCRIBED AND SWORN to before me this February 14,

2020, in the Davao City, with affiant exhibiting to me his Driver’s
license no. L06573824 issued at Davao City on April 12 2019.

Doc. No.____;
Page No.____;
Book No.____;
Series of 2020.
REPUBLIC OF THE PHILIPPINES
REGIONAL TRIAL COURT
11th Judicial Region
Branch 6
Davao City
ELLEN G. ADARNA
Plaintinff,
CIVIL CASE NO._______
-versus- FOR: COMPLAINT FOR
SUPPORT WITH
APPLICATION FOR
ALIMONY PENDENTE
JOHN LLOYD E. CRUZ, LITE
Defendant.
X - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -- - - - - - - - - - - - - - - - - - - - - - - - - - - - - X

NOTICE OF APPEARANCE

THE BRANCH CLERK OF COURT

Regional Trial Court
Davao City – Branch 6

Please enter appearance of the undersigned as counsel for the defendant

JOHN LLOYD E. CRUZ, with his express conformity as indicated below, in this
case. Henceforth, kindly address all pertinent notices to the undersigned at the
address given below.

RESPECTFULLY SUBMITTED.

Davao City, Philippines, February 14, 2020.

ATTY. STEPHANIE M. SANTOALLA

Counsel for the Complainant
Doors 5 & 6, Tropicana Building,
J.P. Laurel Avenue, Lanang, Davao City
Tel. Nos.: (082) 282-3662

REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT
11th Judicial Region
Branch 6
Davao City
ELLEN G. ADARNA
Plaintinff,
CIVIL CASE NO._______
-versus- FOR: COMPLAINT FOR
SUPPORT WITH
APPLICATION FOR
ALIMONY PENDENTE
JOHN LLOYD E. CRUZ, LITE
Defendant.
X - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -- - - - - - - - - - - - - - - - - - - - - - - - - - - - - X

NOTICE OF WITHDRAWAL
OF APPEARANCE

THE UNDERSIGNED LAW FIRM, with the conformity of defendant

JOHN LLOYD E. CRUZ, hereby gives notice of its withdrawal as counsel of
record for said defendant in the above-captioned case and thus, respectfully
requests that henceforth all notices and processes be served upon the accused’s
address on record.

PRAYER

It is respectfully prayed of this Honorable Court that the withdrawal of

the law firm of SANTOALLA and Associates Law Offices be duly
NOTED, and it be relieved of its responsibilities as such.

Such other relief and remedies just and equitable are likewise prayed for.

RESPECTFULLY SUBMITTED.

Davao City, Philippines, February 14, 2020.

SANTOALLA and Associates Law Offices

Counsel for the Petitioner
Doors 5 & 6, Tropicana Building,
J.P. Laurel Avenue, Lanang, Davao City
Tel. Nos.: (082) 282-3662
thesantoalla@associateslaw.com

REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT
11th Judicial Region
Branch 6
Davao City
IN RE: PETITION FOR COMMISSION
AS NOTARY PUBLIC

STEPHANIE M. SANTOALLA Application No. ________

Petitioner,
X- - - - - - - - - - - - - - - - - - - - - - - - - -- - -X

PETITION

The undersigned petitioner STEPHANIE M.

SANTOALLA, unto this Honorable Court, most respectfully
states that:
1. She is of legal age and a Filipino citizen, single,
over twenty-one (21) years old and a resident of Phase 10, Blk
23-D, Sampaguita St., Catalunan Grande, Davao City, copies of
the picture of the petitioner with signature at the bottom part
are hereto attached as Exhibits “A”, “A-1” and “A-2”;

2. She/He is presently residing at

_________________________ and residing therein since
_________ and maintains a regular place of work in the
City of __________;

3. She/He is holding her/his private

law office at
__________________________________________________
____________;

4. She/He has satisfactorily

completed the required course in law at
_________________ in _________ (date of graduation);

5. She/He has passed the _______

Bar Examinations and admitted to practice law in the
Philippines on _________________. Copy of the
Certificate of Bar Membership is herewith attached as
Annex “A” and made an integral part of this petition;

6. She/He is a member of the

Philippine Bar in good standing with Clearances from
the Office of the Bar Confidant of the Supreme Court
and the Integrated Bar of the Philippines. Copy of said
clearances are herewith attached as Annex “B” and
Annex “C”, respectively and made an integral part of
this petition;

7. The undersigned has not been

charged nor convicted in the first instance of any crime
involving Moral Turpitude;

8. She/He desires to be
commissioned as Notary Public for and in
Municipality/City of ____________ and possesses all the
qualifications and none of the disqualifications for said
office;

9. In compliance to the requirements

of the Honorable Court for Notarial Commission,
attached hereto are the following annexes and made an
integral part of this petition:

a. Three Specimen of his/her Official Signature as

Annex “D”;
b. Picture of Desk, Sketch of Prospective Office
and sketch of the location of the office as Annex “E”,
“E-1” and “E-2”;
c. 3 pcs. 2X2 ID picture as Annex “F”;
d. Copy of IBP Membership Payment Receipt as
Annex “G”;
e. Copy of PTR Receipt as Annex “H”.

PRAYER

WHEREFORE, premises considered, it is most

respectfully prayed of this Honorable Court that:

1. The Petition for Commission as Notary

Public filed by the undersigned be acted favorably; and

2. Petitioner be commissioned as a Notary

Public in the Municipality/City of ______________.

Date ____________, Municipality/ City of

____________.

__________________________
Petitioner
 Address ______________________
Contact No.___________________
E-Mail Address ________________
Roll No. ______
IBP No. ______ /Date and Place of Issue
PTR No. _____ /Date and Place of Issue
MCLE Certificate of Compliance No. ____

VERIFICATION and CERTIFICATION AGAINST

FORUM SHOPPING

I, ___________________, under oath, depose and

state that:

1. I am the petitioner in the above-entitled

petition;

2. I have caused the preparation of the foregoing

Petition;

3. The allegations therein are true and correct

based on my personal knowledge and authentic records;

4. To the best of my knowledge, there are no other

pending petitions of the same nature before any court,
tribunal or quasi-judicial agency; and

5. Should I thereafter learn of any similar case

pending before any other court, tribunal or quasi-judicial
agency, I shall promptly notify this court within five (5)
days from discovery.

____________________________
(Name of the Petitioner)

JURAT

SUBSCRIBED AND SWORN to before me in the

_________ on this day of _________ 20___, affiant
exhibiting before me her/his (Government-issued
Identification Card No. ) issued on _________ in
___________.

NOTA
RY PUBLIC

Doc. No. ______;

Page No.______;
Book No.______;
Series of ______.