Republic of the Philippines

____________ Judicial Region

________________ TRIAL COURT

Branch _____, _____________, _____________

COMPLAINT

Plaintiff by the undersigned counsel, and unto this Honorable court, respectfully avers that:

1. Plaintiff and the defendant are wife and husband, respectively, having been married in ______________________________ on __________________________

2. That out of wedlock (number) of children were born namely: _________;

3. Up to (date) the marital relations between the plaintiff and the defendant were harmonious, until (date) when the defendant frequently _______________; (state the sufficient facts entitling the plaintiff to a separate support)

4. In view of the infidelity of the defendant, the plaintiff was compelled to live separately, with her minor children;

5. The defendant earns a fixed monthly income of ______________ pesos; while the plaintiff and her children have nothing, and at present, live on charity of friends;

6. In view of the necessities of the plaintiff and her minor children, the sum of ____ pesos would be a reasonable amount for the support of the plaintiff and her minor children, pendente lite;

7. Plaintiff, without the fault on her part, was compelled to file action for separate support, thereby having incurred the sum of __________ pesos by way of attorney’s fees.

WHEREFORE, it is respectfully prayed that:

1. Pendente lite, the defendant be ordered to pay the plaintiff the sum of __________ pesos per month;

2. After due hearing on the principal cause of this suit, the defendant be ordered to pay the plaintiff by way of regular support and maintenance the sum of _____ pesos, payable on or before the fifth of the month;

3. Plaintiff to recover from the defendant the sum of ________pesos for attorney’s fees and the cost of the suit.

City of Manila, March 23, 2010.

(Sgd.) _____________________________

Counsel for Plaintiff

[Verification and Certification of non forum shopping]