REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

SIXTH JUDICIAL REGION
BRANCH 27
ILOILO CITY

James Dean Reid,

Petitioner,

-versus-

Civil Case No. 03-04-89-024

Nadine Cassandra Lustre-Reid,
For: DECLARATION OF
Respondent.
NULLITY OF MARRIAGE
UNDER ARTICLE 36 OF THE
FAMILY CODE

x-----------------------------------------------------x

PETITION

Petitioner, JAMES DEAN REID, by counsel, respectfully alleges:

1. Petitioner JAMES DEAN REID, is a Filipino, of legal age, married and a resident of Lot
8 Block 21, Dandelion St., Puerto Real Subdivision, Brgy, Gustilo, Lapaz, Iloilo City,
where she may be served with summons and other legal processes;

2. Respondent NADINE CASSANDRA LUSTRE-REID, is likewise a Filipino, of legal

age, married and a resident of Unit 7, 2 nd Floor, Alta Vista Condominium, Barangay
Yapak, Boracay Island, Malay, Aklan, where he may be served with summons and other
legal processes.

3. As compliance with the A.M. No. 02-11-10-SC, as amended, attached hereto are the
following:

a. Sworn Certification of Residency (with house location and sketch) issued by the
Office of the Punong Barangay of Brgy. Gustilo, Lapaz, Iloilo City, Iloilo;

b. Sworn Statement of the undersigned counsel of record that after a reasonable

inquiry, he has verified the authenticity of the petitioner’s proof of barangay
residency showing that the petitioner had been residing in the barangay for at least
six (6) months prior the filing of the petition, and he has sufficiently explained to
 the petitioner the rationale for the residency requirement for purposes of venue
and the consequences of non-compliance therewith; and
4. The venue for the filing of this Petition is with this Honorable Court which exercises
jurisdiction over the place of residence of one of the parties, which in this case, that of the
Petitioner;

5. During their marriage, they have not acquired personal and real properties in the City of
Iloilo and Province of Iloilo under their names;

6. The state of marital relationship of the Petitioner and the Respondent as basis for the
filing of this Petition is hereby discussed below;

7. Petitioner James Dean Reid and Respondent Nadine Cassandra Lustre-Reid love story
started when they met at Kasbar Restaurant and Bar in Boracay Island, Malay, Aklan
sometime in June 2014. The Petitioner was having his vacation as local tourist thereat.
When Petitioner and his friends ordered beer, the manager in the person of the
Respondent took their orders. Petitioner was immediately attracted to her because of her
evenly tanned Morena skin and seductive eyes. Their feelings were mutual and they had
sex that night at the hotel room of the Petitioner;

8. Petitioner thought that it was just a fling. However, considering that they exchanged
mobile numbers, when Petitioner returned to Iloilo City where he resides, they became
lovers. Then, every month, Petitioner visited Respondent in Boracay Island, Malay,
Aklan. Otherwise, the latter would go to Iloilo City to visit the Petitioner. Respondent
would talk to the petitioner about how she was always be courted by a lot men in Boracay
and that she had business acumens of supplying her business. That she came from a well
off family as well. She also told him that she been single for a long time and is looking
for someone to be in a relationship with.

9. Two months from their first meeting, respondent became pregnant. Respondent took the
pregnancy test while in vacation with the Petitioner. They both were surprised and
overwhelmed with the news. Both petitioner and respondent felt that it was not part of the
plan as they have just met each other. However, the said respondent was actually still in a
relationship with her boyfriend Christoper Bariou who was in France at the moment. To
her mind, she did not disclose the information to James for the reason that there had been
no communication between her and Christopher from the day she and the Petitioner met.
Both had agreed during at that time to not get married because of the incident.

10. Petitioner informed his parents about the pregnancy and their decision not to get married.
However, his mother did not want that their future grandchild would grow up illegitimate
because it was a bad image to their family. To placate his parents, he changed his
decision and agreed to marry the Respondent;

11. Together with his parents, Petitioner went to Boracay Island, Malay, Aklan to meet
Respondent’s family and they scheduled the celebration of their marriage on December,
25 2014;
12. Few days after, both had settled at their new home which is Puerto Real, Lapaz, Iloilo
City. Petitioner was surprised to find out that the Respondent had been lying to him all
along and that she was still keeping in touch with said boyfriend. But the respondent
apologized and said they were just talking about closure since she was already getting
married to him;

13. A night prior to the date of wedding, Petitioner tried to cancel the wedding. However, his
father called him through his mobile phone. His father informed him that his actions
would scandalize not only Respondent’s family but also their own. Reluctantly, he
returned and they were married at the Jaro Cathedral Church, Jaro, Iloilo City.

14. After that, they lived together in Iloilo city for few months. Then, their first born child
Marie Antoinette was born on May 3, 2015 at Medical City Hospital, Iloilo City;

15. During their stay in lloilo City, Petitioner had observed that Respondent was very
possessive; she would point a knife at him every time they fight about her insecurities.
She would always be suspicious of everyone surrounding the Petitioner including their
helpers;

16. As a mother and wife, Respondent could not provide the support and care her family
needs. She was suffering from postpartum depression and narcissistic tendency in which
the Petitioner helped her through treatments with psychiatrists. She would also hurt her
daughter when she cries which the Petitioner had witnessed for several times and resulted
to having the child separate from their room for months. He had to hire a nanny to
focused on the child alone and became hands on with taking care of the child himself;

17. Respondent had also been adamantly spending their joint savings, which they acquired
from their wedding and the Petitioner’s parents, on night outs and her vices. Then use it
as well to take on vacations to Boracay island.;

18. Respondent’s family had also been guiding their daughter and will take turns visiting and
staying over for a month at their residence in Iloilo City to help her from her mental
illness. This was also requested by Petitioner and the petitioner’s parents.

19. Then, on April 2016, Petitioner was surprised when she learned that the respondent will
be meeting her ex-boyfriend in Manila. He found about this when he heard the
respondent talking to her ex-boyfriend in secret in the bathroom.

20. In order to salvage their relationship, Petitioner consulted a marriage counselor and had
schedule sessions with the counselor for them to fix the marriage. Petitioner went his way
to woo the respondent everyday and assist her in each therapy session with her
psychiatrist. However, the petitioner still caught the respondent for several times cheating
on him with her ex-boyfriend.
21. Depressed and exhausted with the entire situation, the petitioner had called his in laws
and asked to have the respondent return to her family in Boracay. He asked to keep the
Marie Antoinette, with him since their child is not safe with the respondent.;

22. Petitioner did not communicate with the respondent for a year after that. But respondent
then came to visit them in 2017, she tried again to reconcile with the Petitioner for the
sake of their child, Marie Antoinette. However, the Petitioner already made up his mind
and was traumatized by their marriage. Petitioner decided to file a petition for declaration
of nullity of marriage against the Respondent;

PETITIONER’S PERSONAL BACKGROUND

23. Petitioner was born on May 11, 1989. He is an only child. His father, Jerry Peter Reid,
was agricultural products distributor and a famous business tycoon in Iloilo City. His
mother, Conchita Tan-Reid was an heiress and owner of few hotels in Iloilo City and
Cebu City. Her parents are very religious and conservative;

24. He studied at Paref Westbridge and later at Ateneo de Iloilo in Iloilo City. After high
school, he took up Business Management at the Enderun Colleges in Taguig, Metro
Manila. He was very active in school and she excelled academically during his
elementary and highschool years and grauated with honors. He also took music classes.
He also became a model during his stay in Manila;

25. Petitioner was described as an achiever. He had strong work ethics and goal oriented
person. He doesn’t quit easily through failures, set backs or hardship. This is how also
approached his relationships. He easily falls in love and once he commits, he will do
everything to ensure that the relationship works. He is the sole breadwinner for his child
Marie Antoinette. He had also charity events that benefited the orphans and rape victims
in Chameleon Association and orphanages outside Iloilo City. Presently, he is an
outstanding young entrepreneur awardee by the City Government.

26. After his separation from the Respondent, Petitioner blamed himself. He felt that he was
not able to show enough love and care to the respondent prior to their marriage. He later
accepted that he needed to move on after respondent left their home and the traumatizing
experience during their marriage.;

27. Petitioner sought the services of Dr. Gellada, MD for a psychiatric evaluation to be
conducted on him and his wife. The said physician is qualified in his field of expertise
considering that he is a holder of a license as a physician issued by the Professional
Regulation Commission, a Diplomate of the Philippine Board of Psychiatry and a Fellow
of the Philippine Psychiatric Association. Moreover, he has the educational background,
positions held and accreditations that proved her qualifications as a competent
psychiatrist.

28. The findings of Dr. Gellada in his Psychiatric Evaluation Report showed that Petitioner is
negative for personality disorder. Moreover, he had no behavioral or mental conditions
 that are subject to clinical concern as defined under Diagnostic and Statistical Manual for
mental Disorders 5 (DSM-5);

RESPONDENT’S PERSONAL BACKGROUND

29. Respondent was born on January 19, 1990. Her parents are Johnny Lustre and Annaliza
Crisostomo-Lustre. She was the third of 5 children;

30. Her father was the sole breadwinner. He was small business owner in Boracay but was
bankrupted when his business partner took off with all their money. Her father became
depressed that he turned to drinking and vices to cope with the financial burdens and
raising his family. Her mother on the other hand helped by working as a manager in one
of the hotels in Boracay. Her parents frequently fought and that she and her older sibling
took over in taking care of their younger siblings. On her teenage years, she would hang
out with friends and party just to cope with the toxic family situation.

31. She studied at Yapak Elementary School then at Boracay National High School. She was
able to graduate highschool but did not proceed to college because of the lack of
resources. She would work part time as a waitress and cook. She was then promoted as
manager at Kasabar Restaurant and Bar where she met the Petitioner. However, the
respondent would usually come into trouble after work because she would come home
drunk. She and her parents would usually come to an argument because of her situation.
She would also come to illicit relationships with her customers and would receive
expensive gifts from them. She would also sometimes request money in exchange for
sex;

32. In 2011, espondent then met her ex boyfriend Christopher Bariou and they had a long
term relationship together. Christopher Bariou even stayed in the Philippines for a year
and a half and worked as freelancer. They even lived together in that span of time.
However, her relationship with Christopher Bariou became toxic that she was also her
him physically when she can’t get money from him. Respondent and Christopher Bariou
had to be in a long distance relationship right after that since he was offered a job back in
his hometown in France. The relationship became rocky after that up to the time she met
the petitioner.

33. This Petition filed by the Petitioner is anchored on the ground under Art. 36 of the
Family Code which states that:

“A marriage contracted by any party who, at the time of the celebration, was
psychologically incapacitated to comply with the essential marital obligations
of marriage, shall likewise be void even such incapacity becomes manifest
only after its solemnization.”

34. The marriage of the Petitioner and Respondent is considered void ab initio for the
reason that the latter is PSYCHOLOGICALLY INCAPACITATED to comply
 with the essential marital obligations of marriage even if such incapacities
become manifest only after its solemnization. This was shown after the Petitioner
sought the professional assessment of a psychiatrist;

35. The Psychiatric Evaluation performed by Dr. Gellada, MD, FPPA revealed that
Petitioner is NEGATIVE for psychological incapacity. Respondent, however, is
suffering from NARCISSISTIC PERSONALITY DISORDER;

THE PSYCHIATRIC EVALUATION REPORT

36. The Forensic Opinion and Clinical Impression of Dr. Gellada basing from the data
gathered, Respondent is positive for PSYCHOLOGICAL INCAPACITY considering
that she has a DEPRESSION AND NARCISSITIC PERSONALITY DISORDER. The
DSM 5 Criteria for the disorder is characterized by the following symptoms where the
checks indicate the presence of such symptoms:

A pervasive pattern of grandiosity (in fantasy or behavior), need for admiration, and
lack of empathy, beginning by early adulthood and present in a variety of contexts, as
indicated by fie (or more) of the following:

√ 1. She has grandiose sense of self-importance (e.g., exaggerates achievements

and talents, expects to be recognized as superior without commensurate
achievements).

√ 2. Is preoccupied with fantasies of unlimited success, power, influence,

brilliance, beauty, or ideal love.

√ 3. Believes that he or she is “special” and unique and can only be understood
by, or should associate with, other special or high-status people (or
institution).

√ 4. Requires excessive admiration.

√ 5. Has sense of entitlement (i.e., unreasonable expectations of especially

favorable treatment or automatic compliance with his or her expectations).

√ 6. Is interpersonally exploitative (i.e., takes advantage of others to achieve his

or her own ends.)

√ 7. Lacks empathy: is unwilling to recognize or identify with the feelings and

needs of others.

√ 8. Is often envious of others or believes that others are envious of him or her.

X 9. Shows arrogant, haughty behaviors or attitudes

 √ 10. Feeling very up, high, elated, or extremely irritable or touchy
√ 11. Feeling jumpy or wired, more active than usual
√ 12. Having excessive appetite for food, drinking, sex, or other pleasurable
activities
√ 13. Feeling unusually important, talented, or powerful
x 14. Talking fast about a lot of different things (“flight of ideas”)
x 15. Having a decreased need for sleep
√ 16. Feeling very down or sad, or anxious
√ 17. Having trouble concentrating or making decisions
√ 18. Having a lack of interest in almost all activities
√ 19. Feeling hopeless or worthless, or thinking about death or suicide

Moreover, Dr. Gellada found out that Respondent has seven symptoms of NARCISSISTIC
PERSONALITY DISORDER;

In her findings, this disorder is prominent and its dysfunction significantly affected him and his
marriage due to the following:

a. Respondent has a grandiose sense of importance (Criterion 1). She is preoccupied of

finding true love and being loved unconditionally (Criterion 12) and Excessive
admiration (Criterion 4). She loved to associate with attractive men and act like she
belonged to a higher social status.

She overestimated her importance. She amplified his abilities and demanded
admiration, love and privileges. This is especially prominent during their
courtship period.

Respondent was a manager at Kasbar Restaurant and bar. She always had tourists
come up to her and have one night stands with them. She would always talk about
her achievements to have become a manager of the restaurant and manipulating
these men to spend their money on him. She would also talk about her business
acumens apart from being a manager like a supplier of goods which never
actually existed.

When they went back to Iloilo, Petitioner learned the truth that she had always
been a relationship with Christopher Bariou and it had never ended.

b. Furthermore, Respondent has always been envious of others (Criterion 8)

feeling hopeless and worthless and act of suicide(Criterion 19).

She was suicidal and also had physically hurt other people like ex boyfriend
in the course of their relationship. She would also do the same with the
Petitioner everytime she feels jealous. She would also hurt their daughter
Marie Antoinette
 During their marriage respondent was very possessive of people around the
petitioner that she will fight with them or threat petitioner with a knife. She
would also be caught spending their savings account to spend on partying
and travels to live a life of a single childless woman.

c. Respondent is interpersonally exploitative (Criterion 6) and lacks empathy

(Criterion 7).

She always took advantage of the people around her and has never thought
of their feelings. She would just let the petitioner woo her in order to feel
loved and control him with the said illness. She does not care being in
multiple relationships at once and keep apologizing every time she get
caught without being remorseful of her actions.

ORIGIN AND PERSONALITY STRUCTURE

37. The Respondent’s NARCISSISTIC PERSONALITY DISORDER is a product of early

experiences. Otto Kernberg (1975, 1986) identified parental rejection, deviation and an
outwardly invalidating environment less to the development of narcissism. This is indeed true
with the Respondent. Her father was the sole breadwinner. He was small business owner in
Boracay but was bankrupted when his business partner took off with all their money. Her father
became depressed that he turned to drinking and vices to cope with the financial burdens and
raising his family. Her mother on the other hand helped by working as a manager in one of the
hotels in Boracay. Her parents frequently fought and that she and her older sibling took over in
taking care of their younger siblings. On her teenage years, she would hang out with friends and
party just to cope with the toxic family situation;

Her family was unable to meet his need for attention and love. As a result of repeated parental
rejection, Respondent developed maladaptive schema which includes entitlement, emotional
deprivation, insecurity and insufficient self-control;

Respondent retreated to a fantasized version of himself. She hid his true self which felt
unloved and insecure.

Kernberg noted that a narcissist has a grandiose personality structure. Respondent

idealized true and unconditional love which he demands from people and the world.
Below is the discussion of Respondent’s PERSONALITY STRUCTURE and its level of
functioning:

Her self-identity and self-direction show extreme impairment. Hatred

and aggression are his dominant affect. She disavowed these emotions and
attributed this on others. She devalues others for not loving her. She blamed
them for his problems. For example, she would always get into arguments with
 her parents about her coming home late and drunk. She would also fight with
ex boyfriend for not giving her money everytime she requests one

Her relationships and ability for empathy were also extremely impaired. She is
unable to understand how her lies and grandiosity harm others. For her,
relationships (for example his many girlfriends) were only to satisfy his sexual
and approval needs.

PRESENCE PRIOR TO HER MARRIAGE

38. The presence of Respondent’s Personality Disorder prior to her marriage are manifested
as follows:
a. Lack of remorse as everytime she fought with her ex boyfriend and family and for
using the men he met to provide her needs and as source of income.

b. Grandiosity including exaggerating her accomplishment, relationship status and

business acumens to the tourists and visitors of Boracay Island. She also
associated with them fulfilling his fantasy of being one of the high status and
well-off people.

c. Her need for excessive admiration was fulfilled by her multiple

girlfriends/admirers. To obtain acceptance from others, she frequently drank with
his friends.

SEVERITY AND IMPACT TO MARRIAGE

38. The severity of Respondent’s psychological incapacity has a severe adverse impact to
their marriage:

a. Infidelity and Abandonment. Respondent, while married and supported by the

Petitioner had a paramour with ex boyfriend Christopher Bariou. She planned
meetings and dates through phone and outside Iloilo City.

b. Lack of Support and Care. In the course of their marriage she inflicted
traumatizing experiences and also did not support her daughter and took care of
her. She never even tried to message to check in with her daughter after she left
the house.

c. Respondent and her Depression and Narcissistic Personality Disorder led to her
failed marriage. She prioritized his needs over the needs of her husband and child.
She placed little value on feelings, emotions and the future of others. It had been
and always be all about the Respondent and his wants;

INCURABILITY
39. Three major long-term studies (Collaborative Longitudinal Personality Disorder Study
(CLPS), the McLean Study of Audit Development (MSAD) and the Children in
Community Study (CICS) provided valuable data in the understanding of the life course
of persons with Personality Disorder;

Symptoms of personality disorder will remit and recur during the certain periods
of a person’s in response to treatment and changing life conditions. Sine Respondent
saw no problems and no need for treatment, impairment in social functioning including
marriage may persist;

40. Basing from the above findings, Dr. Gellada concluded and recommended in his
Psychiatric Evaluation Report that:

“NADINE CASSANDRA LUSTRE-REID has NARCISSISTIC

PERSONALITY DISORDER. This prevented him from fulfilling the
essential obligations of marriage to JAMES DEAN REID. His Personality
Disorder was present even prior to their marriage.

NADINE failed to meet the essential obligation of marriage as defined under

Art. 68 of the Family Code. It states that “The husband and wife are obliged to
live together, observe mutual love, respect and fidelity, and render mutual help
and support.”

NADINE is incapable of loving, respecting and being faithful to JAMES. As

narrated by JAMES and his witnesses and confirmed by NADINE herself, she
had multiple relationships before and during her marriage. She never supported
and could not even take just personally take care of her daughter, MARIE
ANTOINETTE when she left.

Overall, NADINE was a difficult partner. She failed as a husband and as a

father. NADINE however did not want to improve his relationship with his
daughter. Based on these findings. I strongly recommend that it is better for the
well being of both parties that their marriage be nullified. Furthermore, support
and counseling to Marie Antoinette should be provided.”

41. The pieces of evidence and testimonies of the Dr. Gellada (as an expert witness) and
ordinary witnesses in this case would establish clear and convincing evidence to prove
the Respondent is psychologically incapacitated vis-à-vis the totality of the Petitioner’s
evidence.

42. While the expert witness had her findings that the Respondent is suffering from
Depression and Narcissistic Personality Disorder, but the latter’s Personality Structure
was also discussed by Dr. Gellada:

“Her self-identity and self-direction show extreme impairment. Hatred and

aggression are her dominant affect. He disavowed these emotions and
 attributed this on others. She devalues others for not loving him. He blamed
them for his problems. For example, she would always get into arguments with
her parents about her coming home late and drunk. She would also fight with
ex boyfriend for not giving her money everytime she requests one.

Her relationships and ability for empathy were also extremely impaired. Sh is
unable to understand how her lies and grandiosity harm others. For him,
relationships (for example her many girlfriends) were only to satisfy her sexual
and approval needs.”

The findings of Dr. Gellada were also supported by the assertions of witnesses
Conchita Tan-Reid who is the mother of the Petitioner and Teresita Guzman who was the
nurse maid of Marie Antoinette;

The manifestations of the personality structure of the Respondent, among others,

which are: (a) her infidelity by keeping a relationship with her ex Boyfriend Christopher
Bariou; and (b) Petitioner’s lack of support and care to their common daughter, are
considered as clear acts of Respondent’s dysfunctionality the undermines his family;

43. In this regard, there is a necessity for this Honorable Court to declare the marriage a
complete nullity under Article 36 of the Family Code;

44. The juridical antecedence of the personality disorder and/or the personality structure of
the Respondent were proven by the expert witness duly supported by the testimonies of
above-mentioned witnesses. The Respondent’s psychological incapacity was existing at
the time of the celebration of the marriage or even before and becomes manifest only
after the celebration. Respondent’s infidelity lack of support and care to their common
daughter, among others, are manifestation of juridically antecedent psychological
incapacity. This manifestation is one of the consequences of the domestic environment of
the Respondent during her childhood years;

45. The psychological incapacity of the Respondent shows a pattern of his failure to be
loving, faithful and supportive to the Petitioner. Her unfaithfulness and infidelity are so
incompatible and antagonistic that will surely cause the inevitable and irreparable
breakdown of her marriage with the Petitioner;

46. It was found out by the expert witness that there is gravity and severity in the
psychological incapacity of the Respondent;

47. The gravity and severity of petitioner’s psychological incapacity has an adverse impact to
her marriage. Respondent’s emotionality and attention seeking severely affected and
eventually destroyed his marriage with the Petitioner. The testimonies of the witnesses
would show serious psychic cause of the part of the Respondent:

a. Infidelity and Abandonment. Respondent, while married and supported by the

Petitioner had a paramour with ex boyfriend Christopher Bariou. She planned
 meetings and dates through phone and outside Iloilo City.

b. Lack of Support and Care. When sh left the Petitioner, she also did not show any
love and care for their child Marie Antoinette. She hurt her physically during the
time they were still living together.

48. Marital obligations are embraced under the following provision of the Family Code:

“Art. 68. The husband and wife are obliged to live together, observe
mutual love, respect and fidelity, and render mutual help and support.

Art. 69. The husband and wife shall fix the family domicile. In case of
disagreement, the court shall decide.
The court may exempt one spouse from living with the other if the latter
should live abroad or there are other valid and compelling reasons for the
exemption. However, such exemption shall not apply of the same is not
compatible with solidarity of the family.

Art. 70. The spouses are jointly responsible for the support of the family.
The expenses for such support and other conjugal obligations shall be paid from
the community property and, in the absence thereof, from the income or fruits of
their separate properties. In case of insufficiency or absence of said income or
fruits, such obligations shall be satisfied from their separate properties.

Art. 71. The management of the household shall be the right and duty of
both spouses. The expenses for such management shall be paid in accordance
with the provisions of Article 70.”

The obligation the Respondent as the wife of the Petitioner and as the
mother to their common daughter are in contrary with or violation of the above
applicable provision of the Family Code;

Her sexual infidelity, unfaithfulness, abandonment, lack of support and

care are clear and patent violation of is marital obligations in favor of the
Petitioner and their common daughter;

49. In this regard, there is a necessity for this Honorable Court to declare the marriage a
complete nullity under Article 36 of the Family Code;

NAME OF THE WITNESSES TO PROVE THE PETITIONER’S ALLEGATIONS

50. The names of the witnesses who will be presented to prove the allegations of the herein
Petition to include the summary of their intended testimonies ate the following:
 Name of Witness Summary of Intended Testimony
1. Petitioner James Dean To prove his allegations in the Petition
Reid.

2. Dr. Gellada To prove that he is an expert witness and she had

rendered a psychiatric evaluation on the parties where
she found out that they have psychological
incapacities known as Dependent and Narcissistic
Personality Disorders.

DOCUMENTARY PIECES OF EVIDENCE TO SUPPORT THE ALLEGATIONS

CONTAINED IN THE PETITION

51. Petitioner will be presenting the following documentary evidence in support to his
allegations contained in the Petition:

ANNEX DOCUMENTARY EVIDENCE

“A” Philippine Passport of Petitioner James Dean Reid bearing Passport No.
P5472660B.
“B” Sworn Certification of Residency.

“C” Sworn Statement of the Counsel on Record.

“D” Certification issued by the City of Iloilo Assessor’s Office, stating

therein that Spouses Nadine Cassandra Lustre-Reid and Zarina Labrador
have no declared real property in Iloilo City.

“E” Certification issued by the Province of Iloilo Assessor’s Office, stating

therein that Spouses Nadine Cassandra Lustre-Reid and James Dean
Reid, have no declared real property in Iloilo Province.

“F” Certificate of Marriage under Registry No. 2011-37 between Nadine

Cassandra Lustre-Reid and Zarina S. Labrador.

“J” Certificate of Live Birth under Registry No. 2011-28467 of Marie

Antoinette L. Reid.

“H” Professional Regulations Commission (PRC) ID Card of Dr. Gellada,

MD, FPPA.

“H-1” Certification as Diplomate, Philippine Board of Psychiatry of Dr.

Gellada, MD, FPPA.
 “H-2” Certification as Fellow, Philippine Psychiatric Association of Dr.
Gellada, MD, FPPA.

“H-3” Written notarized educational background, positions held and

accreditations of Dr. Gellada, MD, FPPA.

“I” Psychiatric Evaluation Report of Dr. Gellada, MD, FPPA.

“J” Judicial Affidavit of Petitioner James Dean Reid

“K” Judicial Affidavit of Dr. Gellada, MD, FPPA

PRAYER

WHEREFORE, in view of the foregoing, after due hearing, it is respectfully prayed that
the Honorable Court render judgment as follows:

1. Declaring the marriage between Petitioner and Respondent null and void ab
initio under the provisions of Article 36 of the Family Code of the Philippines;
and
2. Adjudicating all other legal effects of the decree of nullity of marriage.

Petitioner prays for such other relief just and equitable in the premises.

Iloilo City, Philippines, July 11, 2024.

ATTY. JAMYLLE LUTZ GATON ALITAO

Counsel for Plaintiff

Gaton-Alitao Law Firm, R. Mapa St. Brgy. Tabucan, Iloilo City

Roll of Attorneys No. 141101

PTR NO. 25880, 02/03/24, Iloilo City
IBP NO. 39282, 02/09/24, Iloilo City
MCLE Comp. No. IV-0004567, 02/02/24
REPUBLIC OF THE PHILIPPINES)
CITY OF ILOILO ) Sc.
x------------------------x

VERIFICATION and CERTIFICATION

AGAINST FORUM-SHOPPING

I, JAMES DEAN REID, of legal age, married, Filipino Citizen, and a resident of Block
1A, Zone 15, Tinori-an, Maasin, Iloilo, after having been duly sworn do hereby depose and say:

1. That I am the Petitioner in the above-captioned case;

2. That the allegations in this Petition are true and correct based on my personal
knowledge, or based on authentic documents;
 3. That the herein Petition is not filed to harass, cause unnecessary delay, or needlessly
increase the cost of litigation;

4. That factual allegations therein have evidentiary support or, if specifically, so

identified, will likewise have evidentiary support after a reasonable opportunity for discovery;

5. That I have not theretofore commenced any action or filed any claim involving the
same issues in any court, tribunal or quasi-judicial agency and, to the best of my knowledge, no
such other action or claim is pending therein; and

6. That if I should thereafter learn that the same or similar action or claim has been filed
or is pending, I shall report that fact within five (5) calendar days to this Honorable Court
wherein the aforesaid complaint or initiatory pleading has been filed.

IN WITNESS WHEREOF, I have hereunto set my hand this _______________.

JAMES DEAN REID

Affiant
ID: Philippine Passport
Passport No.: P5472660B
Date of Issue: 17 June 2020
Valid Until: 16 June 2030

SUBSCRIBED AND SWORN TO before me in Iloilo City this July 12, 2024 by the
above-named affiant, who has satisfactorily proven to me her identity through her identification
document (ID: Philippine Passport,; Passport No.: P5472660B; Date of Issue: 17 June 2020;
Valid Until: 16 June 2030 to be the same person who presented and personally signed before me
this VERIFICATION AND CERTIFICATION AGAINST FORUM SHOPPING and attested
that the contents thereof are true and correct; and that she voluntarily executed the same.

Doc. No. : ________;

Page No. : ________;
Book No. : ________;
Series of : 2024.

Copy Furnished by Personal Service:

The Provincial Prosecutor

Iloilo Hall of Justice
Iloilo City
Received By: _______________
Date Received: _____________

The Local Civil Registrar

City of Tacloban
Tacloban Leyte

Received By: _______________

Date Received: _____________

Copy Furnished by Registered Mail with Return Card:

The Solicitor General

134 Amorsolo Street
Legaspi Village
Makati City

Registry Receipt No. _____________

Date: ________________