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REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
NATIONAL PROSECUTION SERVICE
OFFICE OF THE CITY PROSECUTOR
QUEZON CITY

THE PEOPLE OF THE PHILIPPINES,


Complainant,
-vs-

I.S. No. 93875


For: Rape (Art.
335, par (3),
Revised Penal
Code)

IRIS S. ANACLETO,
Respondent.
X----------------------------------------------------------X
ANSWER
COMES NOW, the accused together with the undersigned counsel
to this most honorable court, MOST RESPECTFULLY STATES THAT;
1. On January 5 to January 9, 2014, accused Iris S. Anacleto was
confined to San Lazaro hospital for unusual and disturbing
behavior such as talking relentlessly to himself, head banging
and episodes of depression evidenced by his isolation and
severe melancholic deeds. Exh-1;
2. On January 24, 2014, with the referral of San Lazaro Hospital,
accused Iris S. Anacleto was examined, confined and
managed at the National Center for Mental Health and was
diagnosed with Severe Depression and Schizophrenia and was
discharged on August 3, 2014. Exh-2;
3. Since August 4 of 2014, accused Iris S. Anacleto had been
receiving medications prescribed and ordered by Dr. Joaquin
Cabos of National Center for Mental Health as his
maintenance drug regimen. Exh-3 ;

4. Since the beginning of 2015, due to financial constraints,


accused Iris S. Anacleto had been missing out his drug
treatment and maintenance.

SPECIAL AND AFFIRMATIVE DEFENSE


5. By reason of the findings of the National Center for Mental
Health that accused Iris S. Anacleto had been suffering from
with Severe Depression and Schizophrenia, the accused is
therefore considered insane and hereby interposed the
defense of insanity provided in the Article 12 of the Revised
Penal Code.

PRAYER
WHEREFORE, it is respectfully prayed that this Honorable Court
renders judgment dismissing the complaint with costs against the
complainant.
The accused further prays for such other reliefs and remedies as
may be deemed just and equitable under the premises.
City of Quezon. August 26, 2016.

VERIFICATION AND CERTIFICATION


I, IRIS S. ANACLETO, of legal age, single and a resident of 75
Mindoro Street, Tandang Sora, Quezon City under oath, depose:
I am the defendant in the foregoing case; that I caused the
preparation of the foregoing Answer; that I have read its contents; and
that the same are true and correct of my own direct, personal
knowledge.
Further, pursuant to Rule 7 of the 1997 Rules of Civil Procedure
and existing Supreme Court circulars, I hereby certify that I have not
heretofore commenced any other action or proceeding involving the
same issues in the Supreme Court, the Court of Appeals, or any other
tribunal or agency; that to the best of my knowledge, no such action or
proceeding is pending in the Supreme Court, the Court of Appeals, or
any other tribunal or agency; and that if I should hereafter learn that
other similar or related actions or proceedings has been filed or is
pending before the Supreme Court, the Court of Appeals, or any other
tribunal or agency, I undertake to report that fact within five (5) days
therefrom to this court.

IN WITNESS WHEREOF, he has hereunto affixed his signature


this 26th day of August, 2016 in the City of Quezon.
IRIS S.
ANACLETO
Accused
Drivers License
4335616
SUBSCRIBED and SWORN to before me in the City of Quezon
on 26TH day of August 2016, the affiant showing his Drivers License
4335616 as stated above as competent proof of his identity.
ATTY. MATT TAPANG
Counsel for the defendant
No. 17 Bright Building,
Mindanao Ave. Quezon City
Roll # 77777
MCLE Compliance No. 1230000000
Issued on 11-20-2009
IBP No. 8765432-1-03-2013/ Q.C.
PTR #09179447996; Quezon City
Doc. No. 3
Page No.2
Book No.1
Series of 2016.

EXPLANATION
A copy of this pleading is served via registered mail, instead of
via personal service, on the adverse counsel due to the distance of his
law office address and the lack of field staff of undersigned counsel at
this time.

ATTY. MATT TAPANG