REPUBLIC OF THE PHILIPPINES REGIONAL TRIAL COURT Tenth Judicial Region Branch 7 Bayugan City, Agusan del Sur

BEATRIZ CAMPOS-LONGAQUIT Petitioner. Civil Case No. 0001-2013-A -versusFor: DECLARATION OF NULLITY OF MARRIAGE

DANIEL LONGAQUIT Respondent. x ---------------------------------------------/

ANSWER
COMES NOW, the respondent through the undersigned counsel unto this Honorable Court most respectfully submits his answer and avers that:

THE PARTIES 1. Petitioner Beatriz Campos-Longaquit, is of legal age, married to respondent, Filipino citizen and with present residence address at Miapis St., Bedcor, Brgy. Poblacion, Bayugan City, Agusan del Sur. 2. Respondent Daniel Longaquit, is of legal age, married to petitioner, a Filipino citizen, with residence address at P-5, Poblacion, Sibagat, Agusan Del Sur, where he may be served with notices and other processes; 3. This answer is made by the respondent for the purpose of denying the allegations of the petitioner and show the court his dissent to the annulment of their marriage; 4. Respondent firmly believes that their marriage problems can be solved by means other than this proceeding. 5. The following are the facts and events showing that the respondent does not suffer psychological incapacity;

But the same was neither repeated nor was it brutal. would easily believe those rumors which are utterly unsubstantiated. Respondent’s cruelty and violence 9. It is a sweeping generalization. This allegation is nothing but a complete falsity. there could be no other woman who could be greater or even just equal the beauty and personality of his wife. His good looks and being caring to women is often misunderstood by several of them. The alleged phone calls were nothing but an exaggeration. 7. 15.NON-EXISTENCE OF PSYCHOLOGICAL INCAPACITY A. It should at all times be cherished and protected. 8. 11. 10. Respondent vehemently object to being labeled as a philanderer. rumors about an illicit affair would spread. It is her unfounded jealousy again which prompted her to hurl several accusations against the respondent. in his heart and mind truly and faithfully adore the petitioner. Respondent’s chronic refusal to maintain harmonious family relations and lack of interest in a normal married life and lack of support 12. C. It is utterly false that he does not support his wife and children. It is but a big disgrace and irony that he would want a woman other than his wife. He wanted to spend a lot of time with them. . Herein respondent loves his wife and children. It is only because of respondent’s studies and several jobs that he will sometimes be remiss in his responsibilities as a father and as a husband. as a man of God. 14. Respondent. Respondent’s repeated marital infidelity (philanderer) 6. 13. In his eyes. It was a mere slap in the face with a minimal amount of strength employed. It should not be shattered by mere misunderstanding brought about by insecurities and unfounded jealousy. on the other hand. But this neglect does not amount to a chronic refusal to maintain a harmonious family relation. It is only because of the petitioners prejudice and unfounded jealousy that she could think that those were respondent’s flings or mistresses. Respondent would admit the he hit the petitioner once or twice during their marriage. Miss Beatrice Campos-Longaquit. Respondent believes that the family is the foundation of the nation and the basic social institution. They tend to think that he feels something for them and consequently. It is a settled rule that mere allegation is not tantamount proof. The individuals calling about his whereabouts were his friends. Violence against women runs counter to his conviction and his faith. Respondent. We come to love not by finding the perfect person but by learning to see an imperfect person perfectly. truly believes that a woman is a being worthy of respect and care. This proposition is bereft of evidence. Respondent was only moved to do the same because of the continuous nagging of the petitioner. B.

988. Page No. Respectfully submitted. instead of thinking about separation. 88908768 01-03-2013 Butuan City TIN 546-833-876 Roll No. Respondent may have committed faults as a husband and as a father but those were not enough to severe the relationship tied before our Supreme God. 1798578. Bayugan City. Philippines. Respondent may have caused few bad memories. 18. PRAYER WHEREFORE PREMISES CONSIDERED. ELICANO AND GASTARDO LAW FIRM Unit 2. but petitioner must not forget the thousand good memories that they had together. why not pursue the path to reconciliation. let no one separate. 8600 Butuan City Telefax: (085) 324-5637 By: Atty. 6. 17. 092134567811 . Gastardo Counsel for the Respondent IBP No. respondent most respectfully prays to this Honorable Court that the petition for the declaration of the nullity of marriage filed by BEATRICE CAMPOS-LONGAQUIT be dismissed. Those times when every single moment spent together is like a dream come true. 2012 Mobile No. 4th floor. this 6th day of December 2013. What God has joined together. 8958743 Dec. 79686574 12-19-2012 Butuan City PTR No. XCZ Building Montilla Blvd.16. Thus. Leomil B. Book LXI MCLE No.

. Book No. That the allegations contained therein are true and correct based on my personal knowledge and on authentic documents. married to petitioner. TO THE TRUTH OF THE FOREGOING. . 6. Poblacion. That I have caused the preparation of this pleading. 4. Doc. 8958743 Dec. I am the respondent in this case. Page No. 1. 2012 Mobile No. Leomil B. 3. . 2013 IBP No. 1798578. Page No. with residence address at P-5. No. Book LXI MCLE No. DANIEL LONGAQUIT Respondent SUBSCRIBED AND SWORN to before me this ___ day of __________ 200_ at _________________ affiant exhibiting to me his Community Tax Certificate No. I hereby set my hand this 6th day of December 2013 in Butuan City. 2.____________________ issued on ________________ 200_ at ______________ City. of legal age. under oath. I have fully read and understood the same. a Filipino citizen. Atty. Sibagat. 092134567811 . depose and state. 88908768 01-03-2013 Butuan City TIN 546-833-876 Roll No.VERIFICATION I. Agusan Del Sur. 988. Series of 20__. Philippines. Daniel Longaquit. 79686574 12-19-2012 Butuan City PTR No. Gastardo Notary Public Until December 31..

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