Republic of the Philippines

Ninth Judicial Region

Municipal Trial Court in Cities
Branch______
Zamboanga City
GERARD ANDERSON

Plaintiff,
-versus- Civil Case No. ___123354______

KIM CHUI

Defendant. -for-
x---------------------------------------------x VERIFIED COMPLAINT FOR DIVORCE-
IRRECONCILABLE DIFFERENCES

COMPLAINT
COMES NOW the Plaintiff, by the undersigned counsel, most respectfully allege
that:

The Plaintiff Gerald Anderson residing at (San Jose Gusu Zamboanga City) by way of
Complaint against the Defendant says:

1. SHe was lawfully married to (Gerald Anderson), the defendant herein, on (May
13, 2009) in a (religious) ceremony in City of Zamboanga, Philippines.
2. Plaintiff was a bona fide resident of San Jose Gusu Zamboanga City, Philippines
when this cause of action arose and for more than one year next proceeding the
commencement of this action has been a bona fide resident of San Jose Gusu
Zamboanga City, Philippines
3. The Defendant, KIM CHUI resides at San Jose Gusu Zamboanga City,
Philippines when
4. The parties have irreconcilable differences which have caused the breakdown of
the marriage for a period of six consecutive months.
5. The marital breakdown has continued to the time of the filing of the complaint for
divorce.
6. The differences are of such an extent and nature that it reasonably appears that the
 marriage should be dissolved.
7. There is no reasonable prospect of reconciliation between the parties.
8. There are no children born of the marriage. Nor are there any adopted children or
expected children.
9. There have been no previous proceedings between the parties respecting the
marriage or its dissolution or respecting the maintenance of either party:
WHEREFORE, Plaintiff demands judgment:

A. Dissolving the marriage between the parties

B. For such other and further relief as the Court may deem equitable and just.

GERARD ANDERSON
PLAINTIFFS NAME

I hereby certify to the best of my knowledge, information, and belief that the matter in
controversy is not the subject of any other action pending in any court, or of a pending
arbitration proceeding, that no other action or arbitration proceeding is contemplated,
and I am not aware of any other person who should be joined in this matter.

GERARD ANDERSON
PLAINTIFFS NAME

CERTIFICATION OF VERIFICATION AND NON-COLLUSION PURSUANT

I,Gerald Anderson being of full age, hereby certify:

I am the Plaintiff in the foregoing Complaint. The allegations in the Complaint are true to
the best of my knowledge, information and belief, and the said Complaint is made in
truth and good faith and without collusion for the causes set forth therein. I am aware
that if any of the foregoing statements made by me are willfully false, I am subject to
punishment.
 GERARD ANDERSON
PLAINTIFFS NAME

Other relief as are just and equitable under the premises are likewise prayed for.
City of Zamboanga, Philippines, August 9, 2010.

Counsel for the Plaintiff

Law Office
BG Bldg., Veterans Ave., Zambo. City
Roll No. 45676; 05-23-01; IBP No. 755934 01-05-10
PTR No. 0202604; 01-04-10; Z.C.
MCLE Compliance No. IV-0000169; 02-08-10; IBP, Pasig City

Republic of the Philippines

 Ninth Judicial Region
Municipal Trial Court in Cities
Branch______
Zamboanga City
GERARD ANDERSON

Plaintiff, Civil Case No. ___123354______

-versus-

KIM CHUI Defendant.

x---------------------------------------------x -for-
VERIFIED COMPLAINT FOR DIVORCE-
IRRECONCILABLE DIFFERENCES

DEFENDANT'S ANSWER AND COUNTERCLAIM FOR DIVORCE

Now comes the Defendant, Kim Chui, and ANSWERS as follows:

1. She admits the allegations in paragraphs 1 through 4.

2. She denies the allegation in paragraph 5.

Further, by way of COUNTERCLAIM, Kim Chui, the Counterclaim Plaintiff says:

Counterclaim Plaintiff, who resides at, San Jose Gusu Zamboanga City, Philippines
is lawfully married to the Counterclaim Defendant, who now resides at San Jose
Gusu Zamboanga City, Philippines

The parties were married at Astoria Regency, Pasonanca, Zamboanga City on May
13, 2009 and last lived together in San Jose Gusu Zamboanga City on or about
May 13, 2015

On or about July, 2015, at San Jose Gusu Zamboanga City there came to be and
continues to be an irretrievable breakdown of the marriage of the parties.

Wherefore, the Counterclaim Plaintiff requests that the court:

a) grant her a divorce on the grounds of irretrievable breakdown of the

 marriage pursuant to Muslim Law.

b) order a suitable amount of alimony and an equitable division of the marital

property pursuant to Muslim Law.

c) order the Counterclaim Defendant to provide health insurance coverage for

her.

d) order such further relief as is fair and just.

Kim Chui,
Defendants Name

May 13, 2015

CERTIFICATE OF SERVICE

I, Kim Chui, certify that I have this 13th day of May 13, 2015, served the within
Defendant's Answer and Counterclaim for Divorce on the Plaintiff by mailing a copy thereof to his
attorney, Tommy Lee Jones, Blk 2, Armor Village, Sta, Catalina, Zamboanga City

Signed under penalties of perjury,

Other relief as are just and equitable under the premises are likewise prayed for.
City of Zamboanga, Philippines, August 9, 2010.

ATTY. ARLENE N. FIDEL

Counsel for the Dependant
Law Office
BG Bldg., Veterans Ave., Zambo. City
Roll No. 45676; 05-23-01; IBP No. 755934 01-05-10
PTR No. 0202604; 01-04-10; Z.C.
MCLE Compliance No. IV-0000169; 02-08-10; IBP, Pasig City