Republic of the Philippines

11th Judicial Region

Regional Trial Court
Branch 3
Davao City

LAWRENCE S. DOMINGO,
Petitioner,

Vs. SPEC PRO.NO.________________

FOR: DECLARATION OF
NULLITY OF MARRIAGE
ART. 36 FC and A.M. No.
12-11-10-SC

RACHEL M. DE JESUS,
Respondent

ANSWER

RESPONDENT, through the undersigned counsel before this Honorable court,

most respectfully denies that:

1. Respondent denies all the allegations against her, that such allegation was
being hypothetically made and purely fabricated by Petitioner to escape his
responsibility as a father.

2. That the habitual drinking and going home late manifest only during our late
son was born.

3. That the death of our son was purely accidental as evidence by ANNEX
1,ANNEX 1A, ANNEX 1B

4. That his salary is always short, because he spent it to her other woman as
evidenced by ANNEX 2.

5. That I have my husband even he always acted like that.

6. That the allegations on psychological incapacity against respondent was purely

fabricated, because respondent has no history of mental disease or
psychological incapacity as evidence by ANNEX 3A and ANNEX3B.
 PRAYER

Wherefore, we respectfully prayed in this honourable court that complainant must

be dismissed, and other relief which are just and reasonable are similarly prayed for.

Other relief and remedies as may be deemed just and equitable under the premises
are likewise prayed for.

BENJAMIN A. RECTO

MCLE Certificate No. V-09678

IBP No. 672388, 1/6/2015, Davao City

PTR No. 97328, 1/8/2015

Roll No. 8888

Room 45 Fuentes Building, Jasmin St. Davao City

Contact No: 4833313

Email: benjaminaristorecto@gmail.com

JURAT

SUBSCRIBED AND SWORN to before me this ___ day of January 2016 by RACHEL
M. DE JESUS, known to me personally, who is the same person who signed before me
the foregoing document and who acknowledged before me that he executed the same
voluntarily.

BENJAMIN A. RECTO
Notary Public Until July 9, 2016
MCLE Certificate No. V-09678
IBP No. 672388, 1/6/2015, Davao City
PTR No. 97328, 1/8/2015
Roll No. 8888
Room 45 Fuentes Building, Jasmin St.
Davao City