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Republic of the Philippines

Department of Justice
Office of the City Prosecutor
Makati City

Complainant, Docket No.: C-123456

Under R. A. 9262 or the Anti-
MANUEL RUFINO, Violence Against Women and
Respondent. Children



I, MANUEL RUFINO, of legal age, Filipino, married to

Complainant, BIANCA RUFINO, residing at No. 213 Mayon Street, La
Loma, Quezon City, a Medical Doctor by profession, under oath in
accordance with law, hereby depose and say that:

1. I am the Respondent in the instant Complaint for Economic

Abuse under R. A. 9262 or the Anti-Violence against Women and
Children Act;

2. Paragraphs 3 and 4 of the Affidavit-Complaint are hereby

admitted and adopted;

3. Paragraph 5 of the Complaint-Affidavit is hereby denied for lack

of proof of such display of irrational behavior and that until now, I
have been a responsible husband and father to my family;

4. When I was transferred to Capitol Medical Center, my wife,

Bianca, and I have agreed to rent an apartment in Quezon City so
that we would reside there for some days in week while still
maintaining our house in Makati as our main place of residence. The
purpose for the acquisition of the apartment is for me to be readily
available for the hospital when I am On Call and avoid the hassle of
a long trip from our house in Makati to the Hospital in Quezon City;

5. At first, the arrangement was going well. Eventually, sometime

in the month of June 2015, Bianca and our children opened up to me
that they began to grow tired of living in two houses so I proposed to
them that we should just stay in Quezon City until my residency in the
Capitol Medical Center is done.
6. Bianca rejected my proposal that we should reside in Quezon
City for the duration of my residency in the Capitol Medical Center
saying that she does not like living in Quezon City and the childrens
friends are in Makati. We argued for days and then came to an
agreement that she and the children will stay in our house in Makati
permanently and I will stay in the apartment in Quezon City during
workdays and when I am on call, but will go home to Makati during
my days off and when my work load is not to heavy;

7. The agreement included that I will send them money every time
I receive my salary. She opened a savings account with Banco de
Oro wherein I can deposit money for her and the childrens
allowances. We eventually made the agreement formal on July 16,
2015 and called in Memorandum of Agreement where I will send her
Thirty Thousand Pesos (Php 30, 000.00) per month or Fifteen
Thousand Pesos (Php 15, 000);

8. I admit that I barely was able to go home to my family, but I

have never neglected in giving them their allowances. I deposited
money for their allowances two times every month or whenever I
receive my salary. Copies of the bank deposit slips from July 2015 up
to the present month and the statement of Biancas bank account
from Banco de Oro, duly authenticated by Banco de Oro Makatis
Branch Manager, are hereto attached as Exhibits H and I;

9. The statement in Paragraph 12 of the Complaint-Affidavit is

hereby denied for lack of cause of action for neither have I withdrawn
financial support from my wife and children nor have I prevented
Bianca from engaging in any legitimate profession, occupation,
business or activity. In fact, I have been continuously convincing her
to look for a job or start some kind of business since before we were
married. However, she refuses to do so because she said that she
will dedicate herself to be a full time housewife and mother for our

10. The allegations in Paragraphs 13 and 14 of the Complaint-

Affidavit are hereby denied for being false. The alleged marriage
between myself and one Aida Dy does not exist. The Certificate of
Marriage attached to the Affidavit-Complaint is for another Manuel
Rufino and an Aida Dy who are strangers to me and to our family;

11. For the past three weeks, my wife, Bianca, has refused to talk
with me in person despite my continuous effort to communicate with
her. She also does not to allow me to see my children, causing me
anxiety and to suffer emotional pain;

12. In spite of this Complaint for Economic Abuse that Bianca has
prejudicially filed, and despite the fact that she has emotional and
psychological issues that need to be addressed by seeking
professional help, like her gambling addiction, I still and will continue

to love her and honor the commitment I made with her when we got

13. I have caused the preparation of this Counter-Affidavit.

IN WITNESS WHEREOF, I have hereunto set my hand this 10 th day

of April 2017 at Quezon City, Philippines.


SUBSCRIBED AND SWORN to before me this 10th day of April 2017

in Makati City, Philippines.

Counsel for Respondent

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