revised answer

7/27/2019 Revised Answer

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Republic of the PhilippinesNational Capital Judicial Region

REGIONAL TRIAL COURT

Quezon City, Branch

WILMA BULAKLAK,

Petitioner,

-versus- Civil case No.For: LEGAL SEPARATION

HOWARD FLORES,

Respondent.

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ANSWERS

(PETITION FOR LEGAL SEPERATION)

Defendant, through counsel, answering plaintiffs complaint, alleges:

1. That defendant ADMITS the allegation in paragraph 1 to the effect that they were live at

the same residence, but DENIES that their residence is located in Quezon City when in

fact it is located at Calamba St. Mandaluyong City.

2. That defendant ADMITS the allegation in paragraph 2 to the effect that they were

married, but DENIES as to date when marriage took place and when Dayanara was born.

3. That defendant ADMITS the allegations in paragraph 3, to the effect that petitioner and

defendant start a new life having after the former works as a prostitute; but DENIES that

petitioner was prohibited by defendant from going to work and going out their house,

the fact being after petitioner worked at NAIA and Diamond Hotel respectively,

petitioner always went outside the house during late evening, this time, petitioner

ceased to work and being no reason to prohibit her as there was no work exist.

4. That defendant ADMITS the allegations in paragraph 5 of the complaint, to the effect

that defendant started to throw things around the room; but DENIES that defendant


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undressed her forcefully, the fact remains that being the defendant went to the

apartment where petitioner and his daughter lived, to fetch her daughter but found

nobody, defendant was worried and upset and subsequently start to throw the things

and accidentally broke plates in the kitchen.

5. That defendant is without knowledge or information sufficient to form a belief as to the

truth of the averments in paragraphs 4, 6, 7 and 8 of complaint.

AFFIRMATIVE DEFENSE

1. That, at the time defendant wanted to start a life anew. Defendant looks job for

petitioner. Luckily, with diligence and generosity, of the defendant, petitioner works at

NAIA and Diamond Hotel. Subsequently, her performance came short to the required

standard and failed to observe and, maintain the trust and confidence reposed to her,

after she took something in aircraft on which she worked.

2. That, petitioner work already ceased at that time and she was at liberty to go outside

without telling her husband what time she was coming home, after being asked.

3. That, defendant starts to throw things after he knew that nobody was beside with his

daughter when he intends to fetch his Dayanara for recreation. This is ordinary recourse

a father would do, after being upset and worried when petitioner leaves Dayanara

without any guardian accompanied her in the house.

4. That, petitioner is the one who inflicts injuries during the course of extorting the

amount of twenty thousand from him in exchange of the custody of the child from

Friday to Sunday and withdraw the case gainst him for physical injuiries.


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PRAYER

Wherefore, defendant prays for judgment:

1. Dismissing the complaint with costs against plaintiff.

Defendat assisted by;

Renz Marion M. Mascardo

IBP Roll No. 37658

MCLE No. 3765

Cabuyao, Laguna

CERTIFICATION

I, ___________, of legal age, after being sworn in accordance with law, depose

and state that:

1. I am the plaintiff in this case. I have been duly authorized to execute thisverification and certification.

2. I have read the contents of the complaint and attest that the same are true

and correct based on the authentic records and my personal knowledge.

3. To the best of my/plaintiff's knowledge, no other similar action is pending in

the Supreme Court , the Court of Appeals, Regional Trial Court Metropolitan

and Municipal Trial Court, or any other tribunal or agency, I/plaintiff hereby

undertake to report that fact to this Honorable Court within five (5) days fromdiscovery.

IN WITNESS HEREOF, I have hereunto set my hand this _________.

_____________________________ (Signature of Complainant)


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VERIFICATION

SUBSCRIBED AND SWORN TO before me, a notary, personally appeared the above

person with her respective CTC, who is personally known to me to be the same and/oridentified through competent evidence of identity as defined by Rules on Notarial Practice, who

presented the foregoing instrument in my presence, and took the oath before me as to such

instrument.

Witness my hand and seal this March 1, 2012, in Sampaloc, Metro Manila, Philippines.

NOTARY PUBLIC

Doc. No.: _______

Page No.: _______

Book No.: ______

Series of ________

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