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ANSWER
Attached as Annex “3” are the bank deposit receipts plaintiff received from
the plaintiff’s bank when he deposited money in her account.
10. That defendant partially denies the averment contained in paragraph 15. He
had means to support his family and have been supporting them since 1991.
However, plaintiff was never contented with the amount of money he has been
providing her. Plaintiff would always ask for more and be suspicious that he was
holding back most of the money he was earning. Defendant avers that plaintiff failed
to understand that his business was not prosperous nor making a profit; that plaintiff
failed to appreciate the fact that he was still sending more than he could despite the
fact that his business was going through difficult financial periods. Defendant admits
that while the money he had sent at this time may not have been enough to provide
ample support for his family, he kept providing them nonetheless.
11. That defendant denies the averment in paragraph 16. Defendant has never
been involved in an extra-marital affair. The person respondent was talking to on the
phone was his younger sister, and the gift that he had sent her was for her birthday.
12. That defendant denies the averment in paragraph 17. Defendant was neither
unconcerned and inattentive. The fact that he was present alone during the pre-
operation shows his genuine concern for plaintiff. However, ever since plaintiff
confronted him of his alleged extra-marital affair, despite his explanation, plaintiff
has refused to speak to him, and would only relay messages to him either through
her mother or some other person. With the impending operation respondent avoided
communications with petitioner to prevent stressing her.
14. That defendant admits the averment contained in paragraph 19, with the
qualification that he was uncooperative with Dr. George A. Tan because defendant
felt uncomfortable with him. Defendant tried to convince Pedro Dela Cruz that he
should see Dr. Jonathan B. Grandly instead because defendant was more
comfortable with Dr. Grandly and trusted him. However, Pedro refused.
Nonetheless, despite his brother’s refusal, defendant brought himself before Dr.
Grandly for the same purpose he saw Dr. Tan.
PRAYER
Defendant also prays for other reliefs as may be deemed just and equitable in
the premises.
IN WITNESS WHEREOF, I have hereunto set my hand this 11th day of
March 2019 in Iloilo City, Philippines.
by:
I, JUAN DELA CRUZ of legal age, Filipino, married and a resident of Luna
St., Lapaz, Iloilo City, Philippines, after being sworn to in accordance with law,
depose and state:
3. That the facts stated in the above Answer are true and correct to the
best of my knowledge and authentic records;
4. I have not commenced any action or filed any claim involving the
same issues in any court, tribunal or quasi-judicial agency and to the best of
my knowledge, no such other action or claim is pending in them;
5. If I should learn that the same or similar action or claim has been filed
or is pending after its filing, I shall report that fact within five (5) days from
notice to the court or where the complaint or initiatory pleading has been
filed.
IN WITNESS WHEROF, I have hereunto set my hand this 15th day of March
2019 in Iloilo City, Philippines.
SUBSCRIBED AND SWORN to before me, this 11th day of March 2019, in
Iloilo City, Philippines, affiant exhibiting to me his Philippine Passport No. 987678
issued by the Department of Foreign Affairs in Iloilo City and valid until March 1,
2020.
Copy furnished:
Personal service: