REPUBLIC OF THE PHILIPPINES

6TH JUDICIAL REGION

REGIONAL TRIAL COURT
BRANCH 30
ILOILO CITY

MARTHA MADEAR, Civil Case No. 93226

Plaintiff FOR: SEPARATE SUPPORT
WITH APPLICATION FOR
ALIMONY PENDENTE LITE
- versus -

NOWER MANN,
Defendant

X-------------------------------------X

COMPLAINT

Plaintiff by the undersigned attorney, and unto this Honorable Court,

respectfully avers that:

1. Plaintiff and the defendant are wife and husband respectively, having
been married in Jaro Cathedral, Jaro, Iloilo City, on February 14, 2010;

2. That out of this wedlock, two children were born, namely Lucy Mann
and Prudence Mann;

3. Up to March 10, 2016, the marital relations between the plaintiff and
the defendant were harmonious, until March 11, 2016, when it became
known to the plaintiff that defendant allegedly has had extramarital
affairs with a certain Julia Lennon.

4. In view of this infidelity on the part of the defendant, the plaintiff was
compelled to live separately, with her minor children;
5. The defendant earns a fixed monthly income of seventy-five thousand
pesos; while the plaintiff and her children at present only subsist on the
charity of family, relatives, and friends.

6. In view of the necessities of the plaintiff and her minor children, the
sum of thirty-seven thousand five hundred pesos would be reasonable
amount for the support of the plaintiff and her minor children, pendente
lite;

7. Plaintiff, without fault on her part, was compelled to file action for
separate support, thereby having incurred the sum of five thousand
pesos by way of attorney’s fees.

WHEREFORE, it is respectfully prayed that:

1. Pendente lite, the defendant be ordered to pay the plaintiff the sum of
thirty-seven thousand five hundred pesos per month;

2. After due hearing on the principal cause of his suit, the defendant be
ordered to pay plaintiff by way of regular support and maintenance the
sum of thirty-seven thousand five hundred pesos, payable on or before
the second day of each month;

3. Plaintiff recover from the defendant the sum of five thousand pesos for
attorney’s fees, and the cost of the suit.

ATTY. SEAN GILSIE JIMENEZ

NOTARY PUBLIC for Province of Iloilo
Commission Serial No. 1422303
Until December 3, 2018
The Law Offices of Sean Jimenez
Roll of Attorney 081486
IBP No. 311086/10/31/14/Iloilo City
PTR No. 3052217/ Province of Iloilo
MCLE No. V-18070604
REPUBLIC OF THE PHILIPPINES)
PROVINCE OF ILOILO ) SS.
x----------------------------x

VERIFICATION AND CERTIFICATION

I, MARTHA MADEAR, of legal age, after having been duly sworn in

accordance with law, depose and state that:

1. I am the petitioner in the above-stated case;

2. I caused the preparation of the foregoing petition;

3. I have read the contents thereof and the facts stated therein are true and
correct to my personal knowledge and/or on the basis of documents and
records in my possession;

4. I have not commenced any other action or proceeding involving the

same issue 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; and

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.

________________________
MARTHA MADEAR
Affiant
TIN 47888-531; Iloilo City
 ACKNOWLEDGMENT

(Republic of the Philippines)

City of Iloilo) S.S.

SUBSCRIBED AND SWORN to before me, a Notary Public, for and

in the City of Iloilo, this 5th day of January 2018 personally appeared:

Name Identification Card Issued On/At

Martha Madear TIN ID Iloilo City, 02/01/16

all known to me to be the same person who executed the foregoing instrument
and hereby acknowledged to me that the same is their free and voluntary act
and deed.

This instrument consisting of four (4) pages, including this page on

which this acknowledgment is written refers to a SEPARATE SUPPORT
WITH APPLICATION FOR ALIMONY PENDENTE LITE and has been
signed by the party and sealed with my notarial seal.

WITNESS MY HAND AND NOTARIAL SEAL.

Doc. No.____; ATTY. SEAN GILSIE JIMENEZ

Page No.____; NOTARY PUBLIC for Province of Iloilo
Book No.____; Commission Serial No. 1422303
Series of 20___. Until December 3, 2018
The Law Offices of Sean Jimenez
Roll of Attorney 081486
IBP No. 311086/10/31/14/Iloilo City
PTR No. 3052217/ Province of Iloilo
MCLE No. V-18070604