Republic of the Philippines

National Capital Judicial Region

Regional Trial Court
Pasig City, Branch 70

RIZA MALACA-CRUZ,
Petitioner,

Civil Case No. XX-XXXXX

- versus - For: Declaration of Nullity of
Marriage

LITO C. CRUZ,
Respondent.
x-------------------------------------x

ANSWER

RESPONDENT, by counsel, unto the Honorable Court most

respectfully states that:

1. Paragraphs 1 and 2 are specifically admitted;

2. Paragraphs 3 and 4 are partially admitted. The

Respondent had apologized and the Petitioner has forgiven him for
his shotcomings;

3. Paragraph 5 and 6 is admitted but the Respondent denies

of having knowledge of the Petitioner's pregnancy. It was a suprise
for the Respondent that the Petitioner gave birth which caused the
former to question the fidelity of the Petitioner;

4. Paragraph 7 and 8 is partially admitted. The Respondent

then who was angered by the Petitioner's surprise birth chose to
move out of the house to salvage their marriage by focusing on his
work instead. The Respondent, although unsure of the child's
paternity, still provided for the Petitoner and the child by working in
Pampanga. The Petitioner's visits in his office were wrongly timed
being that they are usually during his busiest at work.

5. Paragraph 9 is admitted but the Repondent declined the

Petitioner's proposal to annul their marriage for reason that it would
be embarassing to his family if he would neglect his own family. The
Respondet futher allege that the marriage cannot be declared null
and void for lack of basis in accordance with the provisions of Family
Code under Article 36.

PRAYER

WHEREFORE, the Respondent most respectfully prays that,

the Honorable Court render judgment dismissing the Petition for
Declaration of Absolute Nullity of Marriage.

Other relief, just and equitable under the premises are likewise
prayed for.

Cainta, Rizal. 25 September 2012.

JILLIAN FATIMA G. ASDALA

Counsel for the Respondent
Roll No. 12345
Unit 214, ABA Bldg., Emerald St.,
Green Park, Sampaloc, Manila
PTR No. 12345; 01/21/11;
Ermita, Metro Manila
IBP No. 12345; 02/04/12; Manila
MCLE Compliance No. III – 12345;
8/01/12
Office No. 6468205/Mobile No.
09214806214

VERIFICATION AND CERTIFICATION OF NON-FORUM

SHOPPING

I, LITO C. CRUZ, Filipino, of legal age, married under oath, states that:
 1. I have caused the preparation and filing of the Petition;

2. I have read all its contents which are true and correct to the best of
my personal knowledge and belief;

3. I further certify that I have not filed any other case with any court,
tribunal or agency involving the same parties and the same cause of action; and

4. If I should learn that another case has been filed involving the same
parties and the same cause of action, I undertaje to report to the Honorable Court
of such fact within five (5) days knowledge thereof.

IN WITNESS WHEREOF, I hereby caused my hand this ______________

at ______________.

LITO C. CRUZ
Affiant

Republic of the Philippines)

Pasig City) S.S.

I certify that on this date, before me, a notary public duly authorized in
the city named above to take acknowledgements, personally appeared the above
affiant who was identified by me through his identification
card:_____________________, a complete evidence of identity to be the same
person described in the foregoing instrument, who acknowledge before me that
his signature on the instrument was voluntarity affixed by him for the purpose
stated therein, and who declared to me that he had executed the instrument as
his free and voluntary act of deed.

IN WITNESS WHEREOF, I hereunto set my hand and affix my notarial

seal on the date and place above written.

ATTY. FATIMA B. CO
NOTARY PUBLIC – CITY OF PASIG
Doc. No. _____ ADMIN No. 2012-009, Until May 1, 2012
Page No. _____ Roll No. 5678
Book No. _____ 14-C- Star St., Legaspi Ave., Binondo, Manila
Series of _____ IBP No. 5678 / 05-04-2012 / Manila
PTR No. 123456 / 08-16-15 / Manila
MCLE Compliance No. 111-4444