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Sixth Judicial Region
Regional Trial Court
CJ Ramon Q. Avancena Hall of Justice
Iloilo City

Civil Case No.___________


For: Annulment of Marriage


COMES NOW, the defendant by the undersigned counsel, respectfully alleges that:
1. Defendant admits that portions of par.1-8 of the complaint regarding the names,
residences, status of the parties, and the prayer stated in the petition but denies
that she is psychologically incapacitated as regard to her marriage with petitioner.
2. Defendant denies under oath that she failed in her marital obligations with the
petitioner but instead, avers that it is the petitioner alone who is psychologically
3. That defendant has persistently demanded that petitioner and her should live
independently both physically and financially from their parents but her pleas were
met on deaf ears.
4. That Petitioner Leouel spent weeks at a time with his parents, without even
communication with the defendant.
5. That Leouel didn’t even contribute to the pre-natal and the delivery of their child
Leouel Jr. Santos.
6. That Leouel spent his wages as a soldier, drinking and roaming around the
province of Iloilo during much of his free time.
7. That the Defendant, Julia Rosario Bedia- Santos tried to patch up her marriage
with petitioner Leouel Santos through the assistance of Dr. Ma. Lourdes Go, a
psychiatrist from November 11,1986 up to the time she left for the United States of
America on January 1,1989. Attached hereto as Annex A are the psychological
sessions attended to by Julia Bedia-Santos and her husband Leouel Santos starting
from November 11, 1986 up to November 11, 1987.

That from that time on Julia Bedia. That on January 1. Ace Macalalag Counsel for the Defendant Co-Counsel for the Defendant MacDo Law Office . That the psychological therapy session undergone by the couple proved to be of no avail in helping Leoel comply with his marital obligations. She sought employment abroad as a subterfuge over the crisis with her marriage to Leouel Santos.5/05/05 MCLE No. a mild but permanent and incurable form of schizophrenia that disables Leouel to comply with his marital obligations. premises considered. it is respectfully prayed that the marriage of the parties be declared null and void from the beginning under Article 36 of the Family Code. Lourdes Go fully determined that Leouel Santos is burdened with Shcnauber Schizophrenia. permission to conduct a series of confidential examinations to learn more of Leouel’s interest so as to better diagnose their problem. Doronila Lead Counsel for the Defendant MacDo Law Office Unit 1. 10. PRAYER Wherefore. Ma. 123456. Lourdes Go had suspicions that her patient Leouel Santos was psychologically incapacitated to perform his marital obligations. she went to the United States to seek employment and to save up money to have her marriage with Leouel annulled due to his psychological incapacity. Lourdes Go on August 14. The psychiatrist asked Julia Bedia-Santos and her husband Leouel Santos. Julia and Leouel consented that the findings are to be made confidential.8.1988.Santos was distraught. Iloilo City Philippines. That on November 21. Attached thereto are the clinical findings and research made by Dr. Attached thereto is the medical contract signed by Dr. 1-001234.01/10/10-Manila Roll No. X Building Recto Manila IBP No. Ma. 11. Dr. Go and the Santos Spouses as Annex B. 1986 as Annexed C.9/09/15 Atty. Petri John L. 08 December 2015 Atty. 12.01/10/10-Manila Ptr No.1234567. 9. After 9 months of further diagnosis and therapy Dr. Ma. 12345. Petitioner also prays for other reliefs as may be deemed just and equitable under the premises. 1987.

Donna Fresnido Lead Counsel 23 Jambalaya St. 1-001234. tribunal. Leganes. I have hereunto set my hand this 8 th Day of December in Iloilo City. If I should hereafter learn that any other similar action or claim has been filed or is pending. after having been sworn to in accordance with law.01/10/10-Manila Roll No.5/05/05 MCLE No.1234567. 1-001234. 123456.5/05/05 MCLE No.1234567. Iloilo City. 3. and a resident of La Paz. or quasi-judicial agency. That I have read the allegations and contents thereof and the same are true and correct based on my personal knowledge and based on authentic records. hereby depose and say: 1.01/10/10-Manila Ptr No.01/10/10-Iloilo Ptr No.Unit 1. Julia Rosario Bedia-Santos. 12345. I shall report that fact within 5 days from knowledge thereof to this Honorable Court.9/09/15 VERIFICATION AND CERTIFICATION AGAINST FORUM SHOPPING I. X Building Recto Manila IBP No.9/09/15 . 123456. IN WITNESS WHEREOF. 2. I hereby certify that I have not heretofore commenced any action or filed any claim involving the same issues in any court. 12345. Philippines Julia Rosario Bedia-Santos JURAT Copy furnished: Atty. IBP No. married. Iloilo. That I have caused the preparation of the foregoing petition. Filipino of legal age.01/10/10-Iloilo Roll No.

counsel for the defendant. Affiant exhibiting to me his driver’s license bearing No. I have hereunto affixed my signature this 9 th Day of December 2015 in the City of Iloilo. Donna Fresnido.S AFFIDAVIT OF SERVICE I. IN WITNESS WHEREOF. the pleading filed in said case as follows: (for personal service) Atty. Juan Dela Cruz JURAT SUBSCRIBED AND SWORN to before me this 9th day of January. 2015 at Iloilo City.5/05/05 MCLE No. Lead Counsel for the petitioner.9/09/15 Doc No.1234567.N11-82-320583 expiring on 10/10/2015 ATTY. 12345.01/10/10-Manila Roll No. 1-001234. Julia Rosario BediaSantos in Civil Case No________. X Building Recto Manila IBP No. Juan Dela Cruz. Leouel Santos. Ace Macalalag. .1. I am the messenger of Att. BREWSKY DORONILA Unit 1. and that as such messenger I served upon the counsel of adverse party.01/10/10-Manila Ptr No. Julia Rosario Bedia-Santos in the case entitled “Leouel Santos vs. 123456. by delivering personally a copy of said pleading upon said lawyer who acknowledged receipt therof as shown by her signature or initial on the said pleading.Republic of the Philippines) City of Manila ) S. under oath declare that: 1. this 9th Day of December 2015.

Book No.2. .Page No.1. Series of 2015.