Republic of the Philippines

SECOND SHARIA CIRCUIT COURT

Third Sharia Judicial District

LEILAH KALA TULAH

Plaintiff,
Civil Case No. 1234567
For: Support
-versusRADWAN LIJA TULAH
Defendant.
x--------------------------------------------x

COMPLAINT
COMES NOW, the plaintiff, LEILAH KALA TULAH, by counsel, and unto
this Honorable Court, most respectfully alleges:
1. That the plaintiff of legal age and a resident of Isabela, Basilan.
Plaintiff may be served with notices, orders and processes of this
Honorable Court through the undersigned counsel.
2. The defendant is also of legal age and a resident of Isabela, Basilan,
where he may be served with summos;
3. That the plaintiff is lawfully wedded wife of the defendant, their
marriage having been solemnized and consummated in accordance
with Muslim law on February 14, 2012 by and before Imam Mohd
Musa Lisan at Isabela, Basilan. A photocopy of the marriage contract
is hereto attached as ANNEX A and made as an integral part of this
complaint;
4. That during the existence of their marriage, begot on March 12, 2013
a child, Fatima Grace, as evidenced by the birth certificated attached
as ANNEX B;
5. In the initial marriage of the plaintiff and the defendant, life was
blissful for the defendant was a good provider to the plaintiff and to
their child;
6. However, this had all changed starting April 2013 when the defendant
accepted an offer to work as a resident Physician at the St. Lukes
Hospital in Manila;
7. In the first two months of the defendant was prompt in sending to the
plaintiff and to their child the monthly support in the amount of Twenty
Thousand Pesos (P20,000.00) as evidenced by the Western Union
Remittances for the month of May and June 2013 attached hereto as
ANNEX C and ANNEX D

8. However, starting July 2013 and onwards, the monthly support given
by the defendant started to become irregular. During the month of
September 2013, the defendant only sent P10,000.00. Attached is the
Western Union Remittance as ANNEX E.
9. When the plaintiff called the defendant to asked why he just sent that
amount, the defendant answered that he needs to pay some
accounts;
10.
From September 2013, the defendant ceases to send the
monthly support for the plaintiff and their child. Worst, the defendant
never went home.
11.
That starting December 2013 and up to the present, despite my
repeated pleas oral and electronic, my husband had altogether
refused to give the support he is obligated to do so for me and for the
child.
12.
That this caused the plaintiff so much emotional financial
distress and was forced to borrow money from the her parents just to
survive;
13.
That starting January 2014, the plaintiff and her child was totally
dependent from her parents for the plaintiff has no means of
livelihood;
14.
That the act of the defendant without any justifiable reason is a
total violation of the provisions of PD 1083 depriving the plaintiff and
the child thier support;
15.
That as a Resident Physician of St. Lukes in Manila, the
defendant earns a montly income of P55, 000.00 , thus there is no
reason that the defendant would deprived the plaintiff and their child
the monthly support thereof.

PRAYER
WHEREFORE, it is most respectfully prayed of this Honorable Court that,
after notice and hearing, judgment be rendered ordering the defendant:
1. To give a montly allowance to the plaintiff with an amount of Twenty
Thousand Pesos (P20,000.00) in advance on or before the 17 th day
of the month;
2. To give the plaintiff, by way of support pendente lite, a montly
allowance of P2,000.00 the first of which to start retroactively to the
first day of this month and the subsequent ones payable in advance
on or before the 17th day of the succeeding month.
3. To pay the costs of this suit.
Plaintiff further prays for such other reliefs deemed just and equitable under
the law.
13 June 2015, Isabela City, Basilan, Philippines.

ATTY. PRINCESS M. AYOMA

Counsel for the Plaintiff
4A Macrohon Building
Balangasan District, Pagadian City
PTR No. 141414, 01-14-10
IBP OR. No. 141414, 01-14-10
Roll No. 141414
MCLE Cert. No. 14141414
(062)955-0683/09088133730
princessayoma@gmail.com
VERIFICATION AND CERTIFICATE
Republic of the Philippines
City of Pagadian

)
) S.S.

I, LEILAH KALA TULAH, Filipino, of legal age residing at Isabela City,

Basilan, after being sworn to in accordance with law, deposes and say:
1. That I am the Plaintiff in the above-entitled case;
2. The facts stated in the above complaint are true and correct to the
best of my knowledge, belief and authentic records;
3. I have not 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
in them.
4. If I should learn that the same or similar action or claim has been
filed or is pending after its filing, I shall report that fact within five
(5) days from notice to the court or where the complaint or
initiatory pleading has been filed.
Pagadian City, Philippines, June 13, 2015.
LEILAH KALA TULAH
Affiant
SUBSCRIBED and SWORN to before me, this 11th of June 2015 in
the city of Zamboang, Philippines. Affiant exhibiting to me her SSS ID No.
234610000000 issued in Zamboanga City on May 25, 2015.

Doc No.
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Page No. ____
Book No. ____
Series of 2015

ATTY. PRINCESS M. AYOMA

Notary Public
Commission Serial No. 1414141414
Until December 31, 2015
PTR No. 141414, 01-14-10
IBP OR. No. 141414, 01-14-10
Roll No. 141414
MCLE Cert. No. 14141414