Republic of the Philippines

REGIONAL TRIAL COURT

8th Judicial Region
Branch 32
Calbayog City

Faeka Tsu
Petitioner,

CIVIL CASE NO. 696

-Versus- For: Annulment of Marriage

Xander Ford
Respondent,
x-----------------------------------x

PETITIONER Faeka Tsu, by counsel, respectfully states:

1. Petitioner is 35 years old, born on October 31, 1982, and a resident

of Magsaysay Street, Calbayog City.

Petitioner is a graduate of Bachelor of Science in Hotel and Restaurant

Management in 2001 from Christ the King College. She had completed
various relevant training in her field that catapulted her to the coveted
position of Hotel Manager at a very young age. Petitioner was the Hotel
Manager at the age of 25 years at Solaire Hotel and Casino in Bonifacio
Global City, Taguig, where she took dedication in her field.

Attached as Annex A hereof is a copy of the Bio-Data of the

petitioner for ready reference.

2. The respondent Xander Ford is 34 years old, born on October 30

1983, and a resident of Mahiwaga street, Biringan City, where he may
be served with summons for the instant case.

Respondent finished Accountancy at a school in Biringan City. While

petitioner knew that respondent was employed with the Bank of
 Kababalaghan in Biringan City from 2003 to 2005, she has no
knowledge of respondents present employment, if any.

3. Petitioner has been employed at the Solaire Hotel and Casino from
2003 until present. She was a Front desk clerk from 2003 to 2004; Event
planner from 2004 to 2005; Concierge from 2005 to 2006; Hotel
Manager from 2006 to present. She holds the record of being the
youngest Hotel manager at a young age of 25 years old of Solaire Hotel
and Casino.

4. Petitioner and respondent first met sometime in 1998. They initially

became text mates from 1998 to 1999 of that year when one of
Petitioners college classmates gave her Respondents mobile number.
However, they eventually lost contact starting 1999 because Petitioner
had to undergo an on the job training at the Crown Regency Hotel where
mobile phones were not allowed while on the duration of the training. By
2000, Petitioner was able to successfully finish her training course and
resumed her communication with the Respondent. In the same month of
2000, Petitioner and respondent met for the first time since 1999 in
Samar Lodge and had a carnal knowledge on the same day.

5. Since then, petitioner and respondent had been seeing each other
once every month. They were already sweethearts when petitioner was
employed in Solaire Hotel and Casino. Their relationship continued via
long distance, with constant calls and emails. In 2001, petitioner &
respondent had their vacation in Biringan City. It was then when she was
introduced by the respondent to his family. The latter warmly accepted
the petitioner.

6. In 2005, respondent started to stay at the house of the petitioner, with

petitioners parents and siblings. Petitioners siblings started to notice
that petitioner and respondent often engaged in verbal arguments over
petty matters. They would shout at each other and no one would want to
back off. Petitioner expected the respondent to give in during fights but
respondent would even get angrier than her, not wanting to lower his
voice.

7. Moreover, Petitioner discovered that Respondent is the dominant and

controlling type. He wanted things his way and would be very angry
when his wants are not granted. Petitioner realized that she and
respondent are incompatible to each other. She already wanted to
separate from him but she could not do so because of her misplaced
and deluded love for him.
8. Petitioner and respondent eventually got married to each other on 2006,
despite the uncertainties already entertained in the mind of the
petitioner, because respondent had already asked the permission of the
petitioners mother for the said marriage. After the nuptial, the couple
continued to establish their dwelling place at the house of Petitioner.

Attached as Annex B hereof is a copy of the Certificate of

Marriage of the parties.

9. While living together as husband and wife, petitioner found out that
respondent was a very jealous and suspicious husband. Whenever
Petitioner arrived home from her work, Respondent would check her
belongings, especially her mobile phone, for any evidence of a probable
infidelity on her part. He suspected her of having an illicit affair with his
co-worker, particularly because they were very close and would always
eat meals together. While petitioner admitted that she is close with her
co-worker petitioner reasoned that such closeness was strictly
professional. However, respondent did not believe the petitioner and he
grew all more suspicious of her actions, accusing her of infidelity even if
he has no concrete basis at all.

10.Despite the fact that their marital relationship was already in shambles
as they continue to engage in heated altercations and fights. Their love,
nonetheless, resulted in the birth of their child, ALIEN who was born on
2007.

Attached as Annex C hereof is a copy of the Certificate of Live

Birth of Alien.

11.Petitioner observed the distance that developed between her and

respondent after the birth of Alien. At first she attributed the said
distance due to her employment, petitioner being not home most of the
time and respondent was left to nurture their child, respondent became
more jealous and more violent towards her.

12. Sometime in 2008, Respondent transferred location to Biringan City

because he did not want to live with petitioners parents and siblings
anymore. In the same year, respondent asked PHP 100,000 from the
petitioner supposedly for the heart operation of Alien. The following year,
he asked PHP 200,000 from her for follow-up operation of their child
Alien. Petitioner had incurred debts just to raise such amount in order to
 improve the health condition of their child Alien. Later on, however,
Petitioner inquired at the OLPHI Hospital with regards to the childs
record and was shocked to learn that no operations were performed for
her child. In fact, their child has no record of consultation on the said
hospital. It was then when Petitioner started to ask the respondent
where her hard-earned income was spent. Since then Petitioner has
been regularly sending adequate amount of monetary remittances to the
respondent. His monthly financial allocations were initially amounting to
PHP 20,000, until it increased to PHP 30,000.

13. Since then Petitioner has been regularly sending adequate amount of
monetary remittances to the respondent. His monthly financial
allocations were initially amounting to PHP 20,000, until it increased to
PHP 30,000. At present, he is sending PHP 50,000 to the respondent on
a monthly basis. Despite these amounts, respondent is not yet satisfied
and even demanded more. He once told the Petitioner that she must
receive PHP 50,000 when she is a Front Desk Clerk, PHP 60,000 as
Event Planner, and PHP 100,000 as Hotel Manager.

14. by hindsight, petitioner feels having gravely victimized by the

respondent thru huge faked hospitalizations of their child Alien.

15. When Petitioner took her vacation in Biringan City in 2008, she did not
stay with the respondent in his house. They were already separated
during this time although she still visited their child Alien in respondent
house whenever it is possible. During her visits, the estranged couple
still engaged in sexual intercourse.

16. Petitioner returned for a vacation in Biringan City in 2009. Petitioner and
Respondent were able to find ways to reconcile the marriage to give the
parties another chance. She thought that the latter would change for the
better but she was just disappointed at him. Petitioner was then
undergoing training for her promotion as Hotel Supervisor while
Respondent was questioning the huge amounts she was paying for the
training. He was also demanding so much time from her amidst the
training. To address the complaint of the respondent, petitioner asked
him to leave Biringan City and stay with her at her abode so that they
could be together more often.

17. However, their relationship became worse than ever, as their

incompatibilities surfaced out again. They engaged all the more in
heated arguments and fights became violent even at the presence of her
 parents and siblings. Petitioner was unable to sleep due to the extended
quarrels with the respondent and she attended her training without
sleep. Petitioner lacks the peace of mind and concentration she needed
for her training. She temporarily found solace in the company of her
female friends, as they engaged in drinking sessions every night, every
after training. When she arrived home, she was pestered by the angry
respondent who continually nagged her.

18. Petitioner expected respondent to be caring and thoughtful towards

her, but he failed to look after Petitioners welfare. He was cold and
apathetic towards her concerns. Respondent could not even kiss her
anymore and would instantly have an angry visage the instant he saw
her face. Moreover, respondent continued to be suspicious of her,
constantly checking her belongings upon arrival from work.
Respondent was selfish, jealous and indifferent. Respondent never
cared for the petitioner and her needs.

19. In the early part of 2009, the couple again engaged in heated fights
when respondent refused to allow the petitioner to attend the wake of
her grandmother in Baguio City. Petitioner could not bring respondent
along with her in the wake because her family and relatives strongly
disapproved of him.

20. During heated fights, Respondent would call his parents and sister in
Biringan City, seeking for sympathy, which the petitioner hated.

21. Their marital fights became all the more frequent and intense until
respondent again move out of petitioner house and went back to
Biringan City.

22. While on Biringan, Respondent created a fake Facebook account of

the Petitioner and added most of her friends, including his co-workers in
the Hotel. Through the said fake account, Respondent was
communicating with her co-workers, telling them that he and his child
was living in a squatters area and are already settling for rock salt as
their meals. Petitioner was infuriated upon learning this because she
was certain that his financial allocations for the respondent and her child
Alien never waned. She still sends them monetary support on a monthly
basis. Petitioner further gathered that respondent also accused her
parents and siblings of sending him death threats. This became the last
straw of their relationship and petitioner finally decided that it is all over.

23. Petitioner believes that their relationship is already beyond repair.

Petitioner did everything she could to save her marriage with the
respondent; however, their incompatibility along with respondents
 pervasively flawed character had made it impossible to redeem the
relationship. Petitioner narrated It was in this premise that Petitioner
finally decided to separate from the respondent; hence the filing of this
annulment case.

24. The parties do not own any properties, whether real or personal.

25. The petitioner has engaged the services of the undersigned

counsel, Demit, Ombina, Tamidles & Associates Law Offices for the
preparation, filing and prosecution of the instant case.

26. The petitioner had engaged the services of Dr. Trina, Clinical
Psychologist, for the determination of psychological evaluation of both
parties, who will be presented as an expert witness in support of the
instant petition.

Attached is Annex D is a copy of the Curriculum Vitae of Dr. Trina,

Clinical Psychologist.

27. The psychological tests administered by Dr. Trina on the petitioner

were: Revised Beta Examination II; Bender Visual Motor Gestalt Test;
Draw a Person Test; Rorschach Psychodiagnostic Test; Sachs
Sentence Completion Test Minnesota Multiphasic Personality Inventory
I; Hand Test; and Self Analysis.

28. Based on the results of the psychological tests and interview on the
parties and corroborator as well as based on the background data
gathered and marital history of the parties, the findings of Dr. Trina are
reproduced in the succeeding paragraphs herein below, culled from
the Report of Dr. Trina, M. A., attached as Annex H hereof, to wit:

After a thorough analysis of the data presented, it is revealed that the

eventual shattering of the conjugal partnership between Faeka Tsu and
Xander Ford is brought forth by the psychological incapacitation of
the Petitioner and Respondent. They were both governed by
debilitating psychological conditions, which made them inept to be
actively part of a relationship where mutuality is founded and required.
Their attitude and behavior are all self-centered in nature that both their
strivings are largely focused to cater their pathological needs and
demands.

29. The reported behavioral manifestations of the petitioner satisfies the

criteria of a PASSIVE-AGGRESSIVE PERSONALITY DISORDER
COMORBID ANTISOCIAL PERSONALITY DISORDER. This
 personality disorder caused the petitioner to be psychologically
incapacitated to comply with the essential obligations of marriage.

30. Dr. Trina characterized the psychological incapacitation of the

petitioner as follows:

Petitioner is described as an emotionally weak-willed woman who

could not directly assert herself to the circumstances and people around
her. From the very start, she has reservations about marrying
Respondent but still pursued with the wedding when she could have
cancelled the ceremony in the first place. Petitioner narrated, tinuloy ko
po ang kasal kahit ayaw ko na sana, naisip ko na gusto ko na iatras nag
kasalpero dahil nakapagpaalam na sa mga magulang namin, itinuloy
na rin. On most occasions while inside the marriage, Petitioner was not
able to stand up against respondent as she lacks the ability to express
power and dominion over circumstances. She allowed her parents and
siblings to dictate the terms to her. Instead of being heard, her decisions
are typically without authority and this made her truly incapable of
leading the family. She is always unsure and filled with feelings of
inadequacy.

Petitioner is depicted as a sullen and argumentative person. She is

always on the defensive side of things so much so that her marital
relationship has been bombarded with heated disputes and fights.
Petitioner is described as madaling magalit, madaldal kapag galit, has a
bad temper. On the onset, she would succumb to existing norms and
standards as these would augment his subjugated disposition and would
probably add quality to her depleted self concept. However, she
internally broods hostile and oppositional feelings which further pave
way to her aggressive tendencies and impulsive predilection when
provoked. She lacked adequate control of her emotions and would direct
them towards the Respondent and their child. During marital disputes,
Petitioner was expecting the Respondent to give in during fights but
Respondent would even get angrier than her, not wanting to lower his
voice. Petitioner narrated, pag galit ako, nasabay siya sa init ng ulo, di
siya papatalo sa akin.

Petitioner sees herself as misunderstood and unappreciated, ill-

fated and demeaned by others. She feels victimized in his situation
without seeing where her shortcomings lie and his own share of negative
contributions why her situation come on such ending and unfortunate
condition. Instead, she just believes that others are seemingly unfair and
are taking advantage of her. Petitioner is illustrated as masyadong
mabait, madaling mapaniwala, masyadong maawain pessimistic as
she is, it has always been her way of thinking that other people never
saw her sacrifices. She thinks that she is receiving lesser appreciation
than what she deserves, and the discontented self-image that she has is
blamed towards the way other people treats her. This makes her all the
more embittered, disgruntled, and disillusioned in their relationship.

Petitioner manifested vacillating emotional condition rendering her

unstable to display adequate reactions to relational stimulations. She
dithers from being the acquiescent and contrite type to the impulsive and
hostile type. She was never consistent with the attitude and behavior
she has shown towards the Respondent. At one point, she would be in
his passive stance. Petitioner and Respondent saw and communicated
with each other last 2016. However, during this time, Petitioner told
Respondent, hindi po niya ipapa-annul ang kasal namin dahil mahal
daw niya ako At another point, she would eventually feel angry to the
extent of threatening the Respondent, even her life. In 2016,
Respondent blackmailed the Petitioner by telling her that he will spread
out her nude photos in his laptop. Respondent narrated, sa totoo lang
po maam, natatakot ako sa mga banta niya dahil alam kong kaya
niyang gawin iyon. Respondent narrated, I can prove his text
messages na papatayin niya ako, papatayin niya kami

Petitioner is pictured as a woman who takes her commitments

lightly. she is emotionally elusive when it comes to her marital difficulties
so much so that she tends to act passively just to preserve emotional
attachment. She may appear conforming but inwardly she is filled with
scorn and contempt for her own incapacity which she often expressed
outwardly by way of passive-aggression and procrastination.

Petitioner lacked adequate insight towards her pathological

condition. This being the case, she failed to evaluate the wrongness of
her actions and was unable to profit from experience. She utilized
rationalization mechanism and offers alibis to place herself in the best
possible light, despite her evident shortcomings or failures. She would
always put the blame on the Respondent while defending his impulsive
and self-centered ways by making justifications of her decisions and
actions. She would even highlight her pathetic condition, being the one
who passively honors her financial obligations, which apparently places
her in a positive spotlight. However, monetary allocations are only part of
her responsibilities as a wife. She may argue that she was making it big
and successful in her career, but she was actually using this as his
scapegoat, allowing her marital relationship to suffer and emotional bond
to really flourish. She was blaming the Respondent, the situation, and
other people, but never herself.
 The personality disorder of the petitioner is a by-product of the
unfavorable experiences and negative exposures she had during her
childhood and adolescent years. On those crucial times, she was just on
her way of establishing the very core of her person and was just building
the permanent foundation of her personality, serving as the grounds of
her current maladaptive behaviors. Growing up, Petitioner had been
accustomed to obey her parents, along with existing house rules. This
being her childhood conditioning, she had learned the value of
obedience and compliance so that she can be accepted and approved
by her perceived society. She desperately tried hard to prove her worth
and this practice of pleasing people made her to repress her own
feelings especially if these are not incongruent with the people she
chose to please.

Alongside, Petitioners compelling self-interests and needs

become stronger as these gain much control of her actions and
decisions. She grew impulsive when it comes to the immediate
gratification of her goals. She became too preoccupied of her own
pleasures that she demanded other people to cater to her every need.
Her increasing self-orientation clashed with her debilitating desire to
perform in order to be accepted by her immediate milieu. These are
poorly integrated into a passive and self-centered person. Though she
may put up a show of efficiency and obedience, her emotion is deemed
lacking in depth thereby sabotaging her relationships.

As no one was there to curb her defective ways, and help her alter
her growing negativism narcissism during childhood until she entered
adulthood, all her erroneous insight and faulty way of perceiving things
made the reference of her current maladaptive behavioral pattern. She is
further found to have no ample consciousness of her defective behavior
which made her laid up to properly function as a responsible, loving,
caring, protective, faithful, trustworthy and understanding wife.

31. The reported behavioral manifestations of the respondent satisfies the

criteria of a HISTRIONIC PERSONALITY DISORDER WITH
UNDERLYING ANTISOCIAL FEATURES. This personality disorder
caused the respondent to be psychologically incapacitated to comply
with the essential obligations of marriage.

32. Dr. Trina characterized the psychological incapacitation of the

respondent as follows:

Respondent has a striking sense of entitlement. He is demanding

of immediate compliance to his desires and would want petitioner to
meet his expectations. He always wanted to feel being treated in a way
where he plays the upper hand in the relationship and would still insist
on what he wants even if it is already impractical. He always wanted the
attention of the petitioner. He demands for her time and money and
requires that he be immediately appeased though he knew that it
impossible to do so. If his wishes are not heeded, he easily bombards
the Petitioner with unnecessary and pointless naggings that are not
helpful in any way. Petitioner discovered that Respondent is the
dominant and controlling type. He wanted things his way and would be
very angry when his wants are not granted. Petitioner narrated, pag
galit ako, lalo niya ako gagalitin, sasabay siya, kaya ko na lang
mananahimik, pakumbaba na lang ako. It was then when Petitioner
realized that she and Respondent are incompatible to each other. He
already wanted to separate from him.

The respondents way of interaction is often characterized by seductive

and provocative behaviors to elicit the response he wanted from her
wife. With his interpersonally attention-seeking ways, he can be in his
flirtatious, vain and exhibitionistic approach to others especially the
Petitioner. They engaged in sexual acts not long after the met each
other personally. He would usually employ dramatic tactics and
emotional trap to manipulate the Petitioner into doing his bidding. He
knew that Petitioner would not be able to stand knowing that their son
are ailing, thus by all means he used it against him to incur money. On
the same year, Respondent asked PHP 100,000 from the Petitioner
apparently for their childs heart operation. The following year, he asked
PHP 200,000 from him for follow-up operation of their child. Petitioner
had incurred debts just to raise such amount in order to improve the
health condition of their child. Later on, however, Petitioner inquired at
the Baguio Hospital with regards the childs record and was shocked to
learn that no operations were performed for the child.

He is an egocentric and pleasure oriented person. He is selfish

and only thinks of his own comfort and happiness, even at the expense
of his marriage and family. He is reluctant to give up selfish indulgence
and failed to be responsible enough to attend to his duties. Arguments
would ensue since he wanted every dime of Petitioners income though
he knew that she also had responsibilities with his siblings. He is
unwilling to share and questions the Petitioner if she ever gives support
to his family. Yet Petitioner would also be disappointed since he never
saved any remittances that she sends to him. He demanded more
money from the Petitioner and was questioning the support she is giving
for childs education. Petitioner argued that prior to getting married; she
had already cleared this with the Respondent. She told him that she will
still support her siblings who sacrificed their education for her to
graduate first so that she can have a job. Supporting them was her way
to pay them back for their sacrifices. However, Respondent took this
negatively and would demand more financial support even if Petitioner
was also giving to her family whenever needed. Respondent would even
pick up a fight with Petitioners youngest sibling with regards the
financial remittances. Petitioner narrated, dahil lang sa biruan,
nagkakaaway sila ng kapatid kong bunso, pikon kasi siya (respondent).
Despite Respondents protests, Petitioner continued to finance the
education of his siblings.

He lacks empathy and is unwilling to consider the feelings of other

people especially the Petitioner. He utilizes rationalization mechanism to
justify his own transgression and blames everything to the petitioner. His
blindness of his own fault made changes impossible in the marriage
since he is not inclined to wear the shoes of the Petitioner. He demands,
carps and argues just to get what he wants without being sensitive that
Petitioner has her own needs too. He wanted to come in sight as the
victim just to make light of his own misdeeds in the marriage wherein
fact it was his poor decisions that has put him in the position.

The personality aberration that respondent is suffering from has its initial
course during the crucial developmental phase in his lifechildhood and
adolescent yearswhere negative experiences and child-rearing
practices severely affects the personality development. In the case of
the Respondent, he grew up without a father figure since his parents
separated when he was a baby and he never communicated with them
again after he left them. Looking at the picture, the young respondent
has developed a strong sense of insecurity and inadequacy in absence
of fatherly affection that he needs. Hence, he grew up compensating for
this insecurity by engaging in relationship with women by being
seductive and provocative in the hopes that they could fill the void that
he has inside only to be always disappointed since they always falls
short to his high expectation. He never realized that they would never
fulfill or quench the emotional insecurity that he has.

Along with this is the lack of fatherly affection comes the lack of
adequate discipline and guidance from his mother who was lenient in his
ways with them especially the respondent. Albeit that they were not
financially well off, her mother indulges his whim and allows him so
much freedom to do what he wants. Punishment and sufficient
disciplinary measures were not provided to him leaving the young
respondent with the defective notion that he has the liberty to do what he
wants. Later on, with the excess freedom given to him, he has come to
believed that he could use anyone at his own disposal, without care for
 his or her feelings and emotions. Since he grew up perceiving himself so
deprived of love, he compensates later on by asserting his bloated self-
esteem to people. He became vain, materialistic and demanding as his
way to appease whatever ineptitude he has. Enjoying a rather unfettered
life due to the absence of effective caretakers, he became dominant and
demanding, as well as stubborn in insisting for what he wants no matter
how impractical it could be. Respondent did not learn to be submissive,
that he would do things without giving consideration on how it might
affect others or his relationships.

With this, due to the absence of proper guidance, and effective

disciplinary means, respondent grew up embracing these maladaptive
responses and turning them as the pillars of her personality.

33. Dr. Trina concluded that the respective psychological incapacities of

the petitioner and respondent speak of antecedence because such
flawed personality began before they entered marriage and manifested
only thereon.

34. Dr. Trina described the respective psychological incapacities of the

petitioner and the respondent as GRAVE, PERVASIVE, SERIOUS,
SEVERE, and PERMANENT rendering it totally beyond repaid despite
available treatments and intervention considering the severity of
petitioners and respondents aberrant psychological conditions, which
makes reconciliation very difficult and impossible.

35. Quoted hereunder is the pertinent part of the Report of Dr. Trina, viz:

Since the psychological aberration of the Petitioner and Respondent

stemmed early in their lives, these have been engraved into their system
making their functioning and adjustments highly defective. Being an
integral part of their wellbeing, such disorders are considered to be
grave, pervasive, serious, severe and permanent rendering it totally
beyond repair despite available treatments and intervention. Likewise,
their psychological incapacitations are noted to be of juridical
antecedence meaning - such flawed personality pattern began before
they entered marriage and manifested only thereon. Considering the
severity of Petitioner and Respondents aberrant psychological
conditions, reconciliation is found to be very difficult and impossible.

36. The diagnosed psychological incapacities of both the petitioner and

the respondent prevent them from mutually performing their marital
duties to each other. In support of this, Dr. Trina states:
 Erstwhile couple, Faeka Tsu and Xander Ford, could never live together
harmoniously as authentic husband and wife with the psychological
incapacitation of both of them. The hope of reconciliation with the hope
of a functional or normal marital union founded on love, respect, trust,
support and commitment is viewed to be uncertain and impossible as
these essential attributes of marriage never existed from the start of the
relationship.

37. Dr. Trina thus recommends that the marriage between the parties be
declared null and void based on the established psychological
incapacitation of both the petitioner and the respondent as follows:

Hence, with much consideration to the findings and discussions made,

the undersigned psychologist humbly requests to this Honorable Court
that their marriage be declared null and void, on the account of
Petitioners psychological incapacitation.

PRAYER

WHEREFORE, premises considered, it is respectfully prayed

that the marriage of the parties be declared null and void from the
beginning under Article 36 of the Family Code.

Petitioner also prays for other reliefs as may be deemed just and
equitable in the premises.
Calbayog City, 2017

Demit, Ombina, Tamidles

& ASSOCIATES LAW OFFICES
Counsel for the Petitioner
Unit 69, JM Square, C. V. Rosales Avenue
Brgy. Payahan, Calbayog City
Tel. Nos. 898-7777
 VERIFICATION/CERTIFICATION AGAINST
FORUM SHOPPING

REPUBLIC OF THE PHILIPPINES)

CITY OF CALBAYOG) S.S.

I, Faeka Tsu , of legal age, Filipino Citizen, married, after having been duly
sworn to in accordance with law, hereby depose and say:

1. That I the petitioner in the above-entitled case;

2. That I have cause the preparation of the foregoing Complaint/Petition and have read
the allegations contained therein;

3. That the allegations in the said complaint/petition are true and correct of our own
knowledge and authentic records;

4. I hereby certify that I have not commenced any other action or proceeding involving
the same issued in the Supreme Court, Court of Appeals, or any other tribunal or
agency;

5. That if I should thereafter learned that a similar action or proceeding has been filed
or is pending before the Supreme Court, court of Appeals or any other tribunal
agency, We hereby undertake to report that fact within five (5) days therefrom to the
court or agency wherein the original pleading and sworn certification contemplated
herein have been filed;

6. I executed this verification/certification to attest to the truth of the foregoing facts and
to comply with the provision of Adm. Circular No. 04-94 of the Honorable Supreme
Court.

IN WITNESS WHEREOF, We have hereunto affixed our signature this 27 day of July
2017, in Calbayog City, Philippines.

Faeka Tsu
Affiant

SUBSCRIBED AND SWORN to before me this 27 day of July 2017, in the City of
Calbayog, with affiant exhibiting to me there SSS ID, with ID No. 1234 issued at
Calbayog City on June 2015.

Atty. Rhoda Calderon

Notary Public

Doc. No.123;
Page No.456;
Book No.780;
Series of 2017.