REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT Batngas City

Branch ___

MARRY ANGELINE DELA ROSA

Plaintiff,

versus Civil Case No. 112334

FOR: Recovery of Actual Damages,
Moral Damages and Attorney’s Fees

____________________
Defendant.

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COMPLAINT

COMES NOW, plaintiff, MARRY ANGELINE DELA ROSA, by counsel and unto this
Honourable Court, most respectfully avers that:

1. Plaintiff, MARRY ANGELINE DELA ROSA, is Filipino, of legal age, single and residing in
Cuta, Batangas City, where she may be served with summons, papers and other
process of this Honourable Court;
2. Defendant, _______________________, is an Iranian, of legal age, single and residing
in 1148 Anacleto St., Santa Cruz, Manila, where he may be served with summons,
papers and other process of this Honourable Court;
3. The defendant met ANGELINE At the start of the 1st semester of AY 2018-19;
4. During the first few days, Defendant is caught by (friend) looking at ANGELINE breaking
a smile and waving at her;
5. About a month and a half into the semester, while [Friend] and ANGELINE sat together
for lunch he approached their table with a rose and kindly asked if they could be left
alone for a moment. From then DEFENDANT professed his feelings for ANGELINE;
6. ANGELINE refused for she has know nothing about the DEFENDANT;
7. After that day, DEFENDANT was persistent and pursue on courting ANGELINE;
8. DEFENDANT would grab his opportunity whenever ANGELINE is left alone. He would
tell her that from the moment he laid eyes of her, he just can’t forget how angelic and
calming the face and eyes of Angeline were. He would also tell Angeline how he is
amused by her hard work and consistency in Med School. He would also left Angeline a
surprising note everyday which contains words of appreciation, complements and how
much he love her and how sure he is that she’s the kind of woman he would want to
spend his life with.
9. Just two (2) months into the courtship, the defendant asked ANGELINE’s hand in
marriage;
10. When ANGELINE consented to finally be wed with the defendant, they both chose
February 8, 2019 to be the date when they would swear before the church and the
community, and show everyone their undying love;
11. ANGELINE traveled back to her hometown in Batangas to share the news with her
single mother. She was accompanied by the DEFENDANT and (friend).
12. ANGELINE’s parents were shocked by the sudden decision of their daughter but they
still accepted it with an open mind and heart.
13. As days passed by, ANGELINE together with the DEFENDANT regularly returned to
Batangas whenever she has a chance;
14. Just before the middle of the semester, DEFENDANT barged into her shared apartment
and started gathering her things and rambling incoherently. After he had finished
packing up her academic resources, personal effects, clothing and other essentials, he
was just hit with a sudden flash of inspiration and on impulse acted on this grand idea of
having her live with him at his apartment. Despite her protests, he would not surrender
the items he had in his possession;
15. Prior to ANGELINE’s encounters with the DEFENDANT and living with him, she had
been a virgin. Early into living together, they stayed in different rooms of the apartment;
16. One night, before they turn in for the night he cuddled her on the sofa. She reciprocated
but not without remarking on this unusual display of affection on his part. Still with her in
his arms, he replied that the apartment now felt like home. Adding that he’d already
sworn to share his life with her and let her into his house, where else will he go if not
back into her embrace. With that, he pulled her into his room and from then on they’ve
been sleeping together;
17. When the semester break came in December, DEFENDANT was invited by
ANGELINE’s Parent to come to Batangas to spend at least a day out of his vacation with
her family, given they were about to be wed. Unbeknownst to the DEFENDANT, [Parent]
had prepared a feast for the coming wedding. Inviting relatives and friends as well as
wedding sponsors. DEFENDANT was informed that everything is reserved and paid
already.
18. (Friend) was also invited. The DEFENDANT was introduced to all the relatives present;
19. After that day, when DEFENDANT is about to commute back to Manila, ANGELINE
asked him of his plans for the wedding and her participation in the planning. To which he
chuckled and reassured her that he was already arranging for the same. By the time she
returns to Manila in January, everything would be ready and all that’s left would be for
her to walk down the aisle;
20. Upon ANGELINE’s return to Manila however, she found him to have grown dismissive
of her. She choked up this attitude to the possibility he was stressed by either his
academics or planning the wedding;
21. A week into her return to Manila, ANGELINE was concerned over the sudden change
and possible stress that the wedding had mounted on him. So she quizzed him on the
matter, trying to get him to open up and ask for her help. However, it only caused him to
grow irate and storm out of the apartment;
22. DEFENDANT left ANGELINE for three (3) days without telling his whereabouts;
23. Upon DEFENDANT’s return, he reeked of liquor and was in a drunken rage as he
shouted that he never wanted to marry her in the first place. Before the situation could
erupt into a fight, he fell unconscious onto the sofa;
24. ANGELINE went to (friend’s) apartment and stayed for the night crying herself to sleep.
25. As days passed by, ANGELINE was worried, seeing no signs of the promised wedding.
She sought out intervention by a barangay officer to ask the DEFENDANT to make good
on the promise and marry her;
26. DEFENDANT admitted that he has a wife in Bulacan and asked ANGELINEto move out
of the apartment.