REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

7TH Judicial Region
Talisay City, Cebu
Branch 10

Ms. TMG
Petitioner,

-versus- CIVIL CASE NO. TCV-2017-143

FOR:
Mr. MPG Declaration of Nullity of Marriage
Respondent.
x-------------------------------------------x

REPLY

PLAINTIFF, herein represented by her Attorney-in-fact, ---, thru the

undersigned Counsel, unto this Honorable Court, most respectfully submits
this Reply to Defendant’s Answer, thus avers that:

1. Defendant, in paragraphs 2 allege that it is always the Petitioner who

asks to have sexual intercourse. Such allegation is not true considering
that she is a pious woman.
2. Defendant, in paragraphs 3 allege that he loves the Petitioner and their
child but such allegation has no basis.
3. Defendant, in paragraph 4 allege that it is always her who initiates
their sexual intercourse, however that same allegation is not true since
she considers herself as again a pious woman who firmly believes that
it should be the husband who should initiate.
4. Defendant, in paragraph 6 the defendant allege that it was a slight
push, however the scar in my head would clearly show that it was not
a slight push.
5. Defendant, in paragraph 6 the defendant allege that it was a slight
push, however the scar in my head would clearly show that it was not
a slight push.
6. Defendant, in paragraph 7 allege that the Respondent DENIES that
Narcissistic Personality Disorder is grave enough to prevent him from
complying with the essential marital obligations, however, This
condition was ingrained from Felipe's "poor parental and family
molding," which caused him to "develop a defective superego and
gross disregard for the feelings of others, particularly his wife
7. Defendant, in paragraph 8 alleges the failure to state cause of action,
such allegation is not correct for the reason that all elements of cause
of action are present.
 WHEREFORE, premises considered, it is hereby respectfully
prayed that the foregoing Reply to Defendant’s Answer be given due
credence and consideration and the reliefs prayed for in the Complaint be
granted.

Finally, Plaintiff respectfully prays for such and other reliefs as may
be deemed just and equitable under the premises.

February 15, 2019, Cebu City Philippines.

Counsel for the Plaintiff

ATTY. MENCHELL RALPH MARGALLO

PTR No. 1234567 1-5-2012
IBP No. 987243 2-21-11
MCLE Compliance No. III-000123
ROLL NO. 31097 7-10-98

COPY FURNISHED:

CLABISELLAS & ASSOCIATES

Attn: Atty. Carmelito Clabisellas Jr.
14th Floor Philamlife Tower
APAS, Cebu City

OFFICE OF THE SOLICITOR GENERAL

Makati City

EXPLANATION

Complainant serves the copy of the foregoing Reply via

registered mail due to lack of office personnel.
ATTY. MENCHELL RALPH MARGALLO