Complaint Jon Gutierrez

Leonelle Mojal-Infante

LEGAL WRITING-February 22,2013

Annulment of Marriage
Page 1 of 5
Republic of the Philippines

SUPREME COURT OF THE PHILIPPINES
8TH JUDICIAL REGION
MUNICPAL TRIAL COURT IN CITIES
BRANCH 99
CABANATUAN CITY
JELAI ANDRES,
Plaintiff,
CIVIL CASE NO. 1234
- versus -
JON GUTIERREZ,
Defendant,
x----------------------------------x
COMPLAINT
COMES NOW, PLAINTIFFS, through the undersigned
counsel and unto this most Honorable Court, respectfully
avers: - THAT –
1. Plaintiff Jelai Andres is a Filipino, of legal age, married,

and is residing at Sampaguita St., Cabanatuan City,
Nueva Ecija.
2. Defendant Jon Gutierrez a Filipino, of legal age, and is

residing at Annapolis Street, Cubao Quezon City.
3. The plaintiff, Jelai Andres and defendant, Jon Guitierrez

were classmates at Wesleyan University.
4. That towards the end of 2004 were Jon and Jelai were
on-and-off sweethearts.
5. The Plaintiff found out that Jon has taken a live-in

partner, whom he had gotten pregnant that lead Jelai to
break up with Jon.
Page 2 of 5
6. However, before Jon got married, he got in touch with

Jelai and tried to convince her to elope with him as he
does not love the woman he is marrying.
7. Jelai rejected the proposal of Jon and told him to take his
responsibility to the other woman and their children.
8. Jelai then changed her number, however, Jon was able

to send her text messages using two different cellphone
numbers, namely, 0920-4769301 and 0921-8084768
which Jelai replied and asked Jon to leave her alone.
9. That, at around June 5, 2005, early in the morning, Jelai

was able to receive a multimedia message service
(MMS) from the number 0921-8084768, one of the
numbers used by Jon, a picture of a naked woman with
spread legs and with Jelai’s face superimposed on the
figure which led her to experience sleepless nights and
mental anguish.
10.Jelai was able to surmised that the picture sent to her

was a picture of her face from a shot he took when they
were in Baguio in 2003.
11.That, after receiving the picture, Jelai got other text

messages from Jon saying: Madali lang ikalat yun, may
chatrum ang tarlac rayt pwede ring send sa lahat ng
chatter.
12.That, upon the arrest of Jon by the police, while being

questioned by the police at the police station Jon
shouted to Jelai: Malandi ka kasi!
PRAYER
WHEREFORE, all premises considered, it is most

respectfully prayed of this Honorable Court for:
Page 3 of 5
1. The acts aforementioned are violative of Republic Act No.

9262 or Anti-Violence Against Women and Their Children
Act of 2004 which provides that
"Violence against women and their children" refers to

any act or a series of acts committed by any person
against a woman who is his wife, former wife, or
against a woman with whom the person has or had a
sexual or dating relationship, or with whom he has a
common child, or against her child whether legitimate
or illegitimate, within or without the family abode,
which result in or is likely to result in physical,
sexual, psychological harm or suffering, or economic
abuse including threats of such acts, battery, assault,
coercion, harassment or arbitrary deprivation of
liberty. It includes, but is not limited to, the following
acts:
xxxx
Section 5 identifies the act or acts that constitute

violence against women and these include any form of
harassment that causes substantial emotional or
psychological distress to a woman. Thus:
SEC. 5. Acts of Violence Against Women and Their

Children. – The crime of violence against women and
their children is committed through any of the following
acts:
xxxx
h. Engaging in purposeful, knowing, or reckless

conduct, personally or through another, that alarms or
causes substantial emotional or psychological distress
to the woman or her child. This shall include, but not be
limited to, the following acts:
xxxx
5. Engaging in any form of harassment or violence;

Page 4 of 5
2. An amount of Php 150,000.00 for moral damages

caused on to Jelai for the sleepless nights and mental
anguish Jan has caused her.
Other awards deemed equitable are likewise prayed for.
28 March 2019. Cabanatuan City, Leyte.
THE LAWFIRM OF
YOUNG AND YU
COUNSEL FOR THE PLAINTIFFS
UNIT NO. 1, 2ND FLOOR, YOUNG BLDG.
240 P. BURGOS STREET, Cabanatuan City, Nueva Ecija
12345678906/ (053) 222-2222.
[email protected]
In behalf of the firm:
EARL ALDWIN S. YOUNG

IBP No. 222222. Jan. 5, 2018, Tacloban City
PTR No. 222222, Jan. 4, 2018, Tacloban City
ROLL OF ATTORNEYS No. 54843
MCLE Compliance No. III-22222, 9 July 2016
MCLE Compliance No. IV-22222, 4 April 2
MCLE Compliance No. V-22222, 4 May 2015
EXPLANATION
In accordance to RULE 13, SECTION 11 of the

1997 RULES OF CIVIL PROCEDURE, the foregoing
COMPLAINT is being filed and served thru
REGISTERED MAIL due to inadequacy of manpower for
personal service.
EARL ALDWIN S.
YOUNG
Page 5 of 5
Republic of the Philippines

City of Cabanatuan s.s.
x-------------------------------------x
VERIFICATION
I, JELAI ANDRES of legal age, Filipinos and residents of
1.Sampaguita St., Cabanatuan City, Nueva Ecija., after being
duly sworn in accordance to law, hereby depose and say,
-THAT-:
1. We are the PLAINTIFFS in the above-entitled complaint.
2. We have caused the preparation of this COMPLAINT and

have read it; and the contents thereof are true and
correct of our personal knowledge and as based on the
records on hand;
3. We further certify that we have not commenced any

action or filed any claim involving the same issue in any
court, tribunal or quasi-judicial agency, and there is no
other action or claim pending therein; that if there is
any such pending action or claim or similar action or
claim is pending, we shall immediately report that fact
to this Honorable Office, within five (5) days from
knowledge thereof;
IN WITNESS HEREOF, I hereunto affix our signatures

this ______________, here in the City of Cabanatuan,
Philippines.
JELAI ANDRES
Plaintiff
SUBSCRIBED AND SWORN TO BEFORE ME, a notary

public for Cabanatuan City, Nueva Ecija this 29 March 2019
here in Cabanatuan City, Nueva Ecija, with affiants exhibiting
their evidences of identity: ________________________________.
Doc. No. ____

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Series of 2018

Complaint Jon Gutierrez

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Leonelle Mojal-Infante

LEGAL WRITING-February 22,2013

Republic of the Philippines

1. Plaintiff Jelai Andres is a Filipino, of legal age, married,

2. Defendant Jon Gutierrez a Filipino, of legal age, and is

3. The plaintiff, Jelai Andres and defendant, Jon Guitierrez

5. The Plaintiff found out that Jon has taken a live-in

6. However, before Jon got married, he got in touch with

8. Jelai then changed her number, however, Jon was able

9. That, at around June 5, 2005, early in the morning, Jelai

10.Jelai was able to surmised that the picture sent to her

11.That, after receiving the picture, Jelai got other text

12.That, upon the arrest of Jon by the police, while being

WHEREFORE, all premises considered, it is most

1. The acts aforementioned are violative of Republic Act No.

"Violence against women and their children" refers to

Section 5 identifies the act or acts that constitute

SEC. 5. Acts of Violence Against Women and Their

h. Engaging in purposeful, knowing, or reckless

5. Engaging in any form of harassment or violence;

2. An amount of Php 150,000.00 for moral damages

Other awards deemed equitable are likewise prayed for.

28 March 2019. Cabanatuan City, Leyte.

In behalf of the firm:

EARL ALDWIN S. YOUNG

In accordance to RULE 13, SECTION 11 of the

Republic of the Philippines

1. We are the PLAINTIFFS in the above-entitled complaint.

2. We have caused the preparation of this COMPLAINT and

3. We further certify that we have not commenced any

IN WITNESS HEREOF, I hereunto affix our signatures

SUBSCRIBED AND SWORN TO BEFORE ME, a notary

Doc. No. ____

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