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Pre Trial Brief Petition For Declaration of Nullity of Marriage
Pre Trial Brief Petition For Declaration of Nullity of Marriage
BHENJO C. BERNARDO
Petitioner,
GRETCHEN B. GENOVEZA-BERNARDO,
Respondent,
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PRE-TRIAL BRIEF
Petitioner alleges in his Petition, viz: a) that petitioner and respondent are
husband and wife; b) that both respondent and petitioners are clinically found to be
psychologically incapacitated to comply with the essential requisites of marriage
identified as Narcissistic Personality Disorder with Anti-Social Traits while
respondent is suffering with Histrionic Personality Disorder; c) that the root cause of
such illness is traced from their respective childhood; d) such illness is diagnosed to
be grave and incurable; e) that such illness existed prior to the marriage and
became apparent at the time of the marriage.
Petitioner likewise alleges that a child was born in wedlock and their de-facto
separation which culminated from petitioner’s frustration of respondent’s mercurial
change of disposition, abusive and manipulative conduct, immaturity, excessive
spending and adulterous conduct. That respondent failed to give love, emotional
support and fidelity to the marriage.
ABSTRACT OF TESTIMONIES
Petitioner will be testifying on the allegations in the Petition and will present
documentary evidence.
Page 02.
ADMISSIONS
ISSUES
Counsel will be available for trial on dates convenient with this Honorable
Court.
Respectfully Submitted:
Copy furnished:
Office of the City Prosecutor ------------------- Personal Service
Quezon City
EXPLANATION
Pursuant to the Provision of Rule 13, Section 11 of the 1997 Rules in Civil Procedure as
Amended, undersigned submits this Explanation that the service of this Pre- Trial was to Office of the
Solicitor General by Registered Mail instead of personal serve in view of lack of manpower.