REPUBLIC OF THE PHILIPPINES
DEPARTMENT OF JUSTICE
NATIONAL PROSECUTION SERVICE
OFFICE OF THE PROVINCIAL PROSECUTOR OF BOHOL
Hall of Justice, Tagbilaran City
SARAH A. URSOS,
Petitioner,
-Versus- Civil Case No. ________________________
For: Declaration of Nullity of Marriage
J-ELSON C. URSOS,
Respondent.
x---------------------------------x
PETITION
COMES NOW petitioner, by the undersigned counsel and unto this Honorable Court,
most respectfully alleges:
1. Petitioner is of legal age, Filipino citizen and a resident of G Hotel Hontanosas
Road Totolan Dauis, Bohol while respondent is likewise of legal age, Filipino
Citizen and a resident of Poblacion 3 Tagbilaran City, Bohol where he may be
served with summons, orders and other legal processes of this Honorable Court;
2. Petitioner and respondent are husband and wife, having been legally married on
February 14, 2013 at St. Joseph Cathedral Poblacion 2 Tagbilaran City, a copy of
their marriage certificate is hereto attached as Annex “A’’;
3. The Couple has Three Children namely: Lylle Stephanie A. Ursos age 10, Zuehan
Steven A. Ursos,aged 7; and Gin Ruwi A. Ursos, aged 3. Copies of their birth
certificates are hereto attached as Annexes “B’’, “C’’ and “D’’, respectively;
4. Petitioner and respondent were classmates during their college years at Holy Name
University taking up Bachelor of Science in Nursing and both graduated on March
2006. They were both employed at Holy Name University Medical Center as staff
nurses.
5. Due to high cost of living with their three (3) children, they ventured on an Ice
Cream Business in Totolan Dauis,as business partners to sustain their growing
family.
6. Aside from being business partners, they were likewise attracted to each other
physically, although there were no emotional attachments to one another, they
frequently indulged in sexual intimacies which resulted in the petitioner’s frequent
pregnancies. Petitioner did not want to marry respondent for he knew him to be
promiscuous, having a long list of girlfriends during their college years. He
however promised to support their children.
7. When petitioner’s parents, who were devoted Catholics, came to know that they
were living together for long time and had 3 children, they demanded their daughter
to marry the respondent herein. Despite her disagreement, they were married in
haste and in simple church ceremony.
8. Unprepared to face the rigors of married life and with no visible means of
livelihood, the couple live with the petitioner’s parents. Their first month of being
married was in a roller coaster ride with frequent violent fights and disagreements
as they were not really in love with each other.
9. Years past, petitioner flew to Canada to work as Hospital Nurse in the Columbia
State Hospital British Columbia. Petitioner sent money to respondent to support
their kids and only to find out that the respondent spent the money for his whims
and caprices.
10. Petitioner later found out that respondent had illicit affair of one Crister Jane
Clemana through the petitioner’s friend Charlotte Bag-ao Dee who have seen and
saw the respondent and Crister Jane living together in an apartment near the
petitioner’s house.
11. Respondent then denied the allegation and told the petitioner that Crister is his cousin.
12. Before her tourist visa expired, petitioner came back to the Philippines and attempted to
reconcile with respondent especially after seeing their three (3) children. Respondent
refused to live again with petitioner.
13. Time went by with the parties living separately on their own. It became convenient for
both to live separately as they would constantly fight when they are together.
14. This arrangement went on until petitioner’s student visa was approved in Canada and she
was slated to leave for Canada sometime August 2017. Before she left, she talked with
respondent and they both agreed that they will both use the time away from each other
to think things over and determine if there is still a chance for them to get back and live
together as husband and wife when petitioner comes back from her studies abroad.
15. To date, they have gone separate ways and there is no hope for reconciliation.
16. Petitioner, convinced of the futility of her efforts, decided that she deserves to start a
new life with feelings of hope.
17. Petitioner then engaged a clinical psychologist who conducted psychological evaluation
on the ability of respondent to cope up with the essential obligations of marriage. After a
thorough evaluation, respondent was found to be psychologically incapacitated to
perform the essential marital obligations of marriage born from his lack of maturity, which
affected his sense of rational judgment and responsibility. These however is manifested
under Article 36 of the New Family Code of the Philippines appropriately and clinically
known as “Anti-social and Narcissistic personality disorder;
18. Petitioner is filing this petition to declare his marriage a nullity. Respondent showed no
concern for his obligation towards his family in violation of Art. 68 of the New Family Code
which provides that husband and wife are obliged to live together, observe mutual love,
respect and fidelity and render mutual help and support.
19. That said psychological defect or illness is grave, serious and incurable and existed prior
to the marriage and became manifest during its existence.
PRAYER
WHEREFORE, premises considered, it is most respectfully prayed that the marriage of the
petitioner with the respondent be declared a nullity. It is likewise prayed that if and when parties
are able to enter into an extrajudicial settlement as to the custody of the minor children and joint
parenting, the same be adopted by this Court and in the absence thereof, a fair and just
settlement of their rights and obligations as parents be adjudicated by this Honorable Court.
We pray for such other reliefs, just and equitable under the premises.
December 7, 2023 Tagbilaran Ciity, Bohol Philippines
ATTY. LAWRENCE UY
Counsel for Petitioner
Al Fresco Bay, Poblacion 1 Tagbilaran City Bohol
IBP No. 10836386873 dtd. 01-07-23 Tagbilaran
PTR No. 27863753 Tagbilaran Bohol
Roll No.282786
MCLE Compliace II-0006252
Dtd. April 11,2023
VERIFICATION
I, SARAH A. URSOS, of legal age, under oath, states:
1. That I am the petitioner in this case and that I have caused the preparation of the
same petition;
2. That I attest to the truth of all the allegations in the same petition of my own personal
knowledge;
3. In compliance to the Supreme Court Circular against forum shopping, I hereby certify
that: a) I have not commenced any other action or proceeding involving the same
issues before the Supreme Court, or the Court of Appeals, or any other tribunal or
agency; b)to the best of my knowledge, no such action or proceedings is pending in
the Supreme Court, Court of Appeals or any other tribunal or agency; c) If I should
learned that similar action or proceeding has been filed or is pending before such
tribunals or bodies, I shall report that fact within (5)days therefrom to the court of
agency where the original pleading and sworn certification have been filed.
SARAH A. URSOS
Affiant
SUBSCRIBED AND SWORN to me before this 7th day of December 2023, affiant
exhibited to me her TIN No. 839-939-329-000 dated January 7, 2002 issued in Tagbilaran City, Bohol
Philippines.
Doc. No. 23
Page No. 8
Book No. 12
Series of 2023.
