Professional Documents
Culture Documents
Complaint
Complaint
Complaint
Jacqueline B. Derrida
Plaintiff,
PSSg.Niccolo G. Machiavelli,
Defendant.
x-----------------------------------------x
COMPLAINT
Page 1 of 10
started the small talks engagement which later
led to the invitation of breakfast by the Plaintiff;
c) During the said breakfast, the Defendant
proudly shared his personal information, which
includes, but not limited to, his name, age,
occupation, and even his personal address;
d) To the surprise of the Plaintiff, the herein
Defendant is fifteen (15) years younger than
her;
e) Because of the representation of the Defendant,
the Plaintiff allowed the Defendant to court her.
f) On 27 March 2023, the Plaintiff gave her sweet
answer agreeing to their terms as boyfriend and
girlfriend;
g) On 01 April 2023, the Defendant prepared and
proposed for marriage to the Plaintiff. To
strengthen his proposal, he was able to provide
the Plaintiff, a copy of his Certificate of No
Marriage attached herein and made integral as
Annex “A”;
h) Thereafter, preparation for the wedding
ensued. Attached herein and made integral part
as Annex “B-Series” are the receipts therefor
which includes:
• reservation and full payment of the
beachfront for the ceremony;
• full payment for all the decorations;
• full payment for the customized 60-
minute fireworks display;
• full payment through bank transfer for
the wedding gown of the Plaintiff;
• full payment through bank transfer
gowns for the bridesmaids;
• full payment for the wedding cake
including its delivery fee;
• full payment for the Plaintiff’s wedding
shoes;
• full payment of the wedding rings with
12 diamond studs each;
• full payment for the catering services;
• full payment for the wedding
invitation;
• payment for the personalized jewelry
souvenirs;
Page 2 of 10
i) On 05 April 2023, the Plaintiff and Defendant
sent out wedding invitations to their respective
guests attached herein and made integral as
Annex “C”;
j) Between 02 April 2023 to 09 April 2023, the
Plaintiff noticed of the Defendant’s activity,
being in constant phone conversations with an
unknown woman. The Plaintiff believed in good
faith to the reason of the Defendant,
representing the said woman as Defendant’s co-
officer, a policewoman, who was giving
Defendant updates about work;
k) On 07 April 2023, Jojo Gacayan, Plaintiff's
personal driver witnessed the Defendant and a
woman coming out of Golden Park Inn in
Bauang, La Union.
l) Jojo Gacayan informed that the Defendant and
the said woman showed an intimate
relationship to wit a reasonable person would
find it scandalous considering that the
Defendant is publicly known as engaged with
the Plaintiff. Attached hereto is the Affidavit of
the aforementioned witness as Annex “D”.
m) On 11 April 2023, Plaintiff received a phone call
from a certain Pat. Katrina Almirol-Nonesa,
informing Plaintiff that she is a co-officer of the
Defendant, and out of conscience, admitted
that the Defendant often brings a certain
woman named Nica Difuntorum during night-
outs and drinking sprees after duty. She alleged
that the Defendant and Nica are involved in an
intimate relationship. Attached hereto is the
Affidavit of the aforementioned witness as
Annex “E”.
n) The Plaintiff confronted the Defendant of his
infidelity. Rather than denying, Defendant
begged for a second chance.
o) Disheartened, Plaintiff decided to terminate the
wedding preparations and not to proceed with
marriage but Defendant strongly convinced
Plaintiff to continue therewith.
p) Plaintiff immediately paid for all unsettled
accounts because the Defendant will be on
training in Laguna for four (4) months after
their wedding on 11 June 2023.
q) By 11 April 2023, when the wedding details
Page 3 of 10
were posted by Plaintiff’s Social Media
Manager, the occasion garnered the attention of
the general public and became highly
anticipated due to the expensive suppliers and
distinguished personalities invited;
r) On 12 April 2023, the Defendant decided to
walk out of the engagements. Defendant
informed the Plaintiff that he is no longer
interested and refused to enter marriage with
her, reasoning that he cannot live with a wife
who does not trust him;
s) On 12 April 2023, Jessica Lanuza went to the
residence of the Plaintiff and confessed to her
intimate relationship with the Defendant and to
their plans to still be in a relationship despite
the Defendant’s marriage to the Plaintiff. Ms.
Lanuza further claimed that they intended to
use the Plaintiff as leverage to extract money
from plaintiff afte the wedding. Ms. Lanuza said
that the Defendant was seeing Nica
Difuntorum, another woman, and that it was
the resentment she felt which motivated her to
come forward. Attached hereto is the Affidavit
of the aforementioned witness as Annex “F”;
t) On 13 April 2023, because of intricate and
personalized details specially made for the
wedding, the suppliers were precluded to make
necessary refunds to the Plaintiff. As such, the
Plaintiff demanded the Defendant to pay the
expenses incurred, but the Defendant
adamantly refused resulting in great damage
and prejudice to the Plaintiff.
u) On the same day, Plaintiff, in her desire to
amicably settle the matter, filed a complaint
with the Barangay Lupon for conciliation but no
settlement was reached since Defendant did not
appear during said meeting. A Certification to
File Action was issued by the Barangay Lupon
and the same is attached hereto as Annex “G”;
v) On April 14, 2023, the Plaintiff wrote a Demand
letter for the payment of expenses which were
settled in full during the wedding planning and
preparation. A copy of the Demand letter is
attached and marked as Annex “H” and made
an integral part of this Complaint.
w) To this point in time, the Defendant did not
accede to any demands made by the Plaintiff.
Page 4 of 10
4. As such, the manifest bad faith on the part of the
Defendant would reveal that he is liable for the damages incurred by
the Plaintiff.
said:
Page 5 of 10
good customs for which Defendant must be held
answerable in damages in accordance with Article
21 of the Civil Code. (Emphasis supplied)
Page 6 of 10
b. And, Article 2199 provides:
Page 7 of 10
WHEREFORE, premises considered, it is respectfully
prayed of the Honorable Court that:
Page 8 of 10
REPUBLIC OF THE PHILIPPINES)
BACNOTAN, LA UNION) S.S
x------------------------------------------------------x
VERIFICATION/CERTIFICATION
OF NON-FORUM SHOPPING
Page 9 of 10
IN WITNESS WHEREOF, I have hereunto set my hand this 22 April, 2023 in
the Municipality of Bacnotan, La Union Philippines.
JACQUELINE B. DERRIDA
Affiant
Passport ID: POOOOOOOOA
Bacnotan, La Union
Juan P. Emmortal
Notary Public
Roll No. 63523-June 12, 1988
IBP Lifetime No. 0154326/
03.04.2000
MCLE No. I-0000123654
Series of 2023.
Page 10 of 10