REPUBLIC OF THE PHILIPINES

REGIONAL TRIAL COURT

DESIGNATED FAMILY COURT
NATIONAL CAPITAL JUDICIAL REGION
BRANCH 1, MANILA

JUAN PAOLO DE LA CRUZ

Petitioner,

-versus- CIVIL CASE NO.E13

For: LEGAL SEPARATION

JUANITA DE LA CRUZ
Respondent.
x-----------------------------------------------x

ANSWER

DEFENDANT, thru the undersigned attorney, unto this Honorable Court, most
respectfully states that:

1. The allegations made under paragraph 1, 2, 3, 4 and 5 of the complaint are

admitted;

2. The allegations made under paragraph 6 of the complaint are not admitted. The
defendant did not have sexual intercourse with another man in the conjugal dwelling, as
alleged in the complaint. The man referred to caught inside the conjugal room was
Dodong Pascual, the family driver, who was asked by the defendant to fix the room’s
airconditioning unit;

3. The allegations made under 7 to 10 are deemed admitted.

NEGATIVE AND AFFIRMATIVE DEFENSES

Defendant hereby re-pleads and incorporates the foregoing averments and as

negative and affirmative defenses state THAT:

1. There is no sufficient evidence to prove that Defendant was caught having

sexual intercourse with another man, as no visitors were present in the house
on the day alleged to have been the day when the unlawful act was committed.
The Defendant is innocent of the act imputed upon her, and stresses that this
complaint was maliciously filed against her honor, as she earns more money
than her husband, and is more successful in her career as a designer, than her
husband, who has been suspended from his duty as a police officer.
 WHEREFORE, it is most respectfully prayed of this Honorable Court that
judgment be rendered granting other relief and remedies that are just and equitable in this
instant case.

Respectfully submitted, February 5, 2010. Manila, Philippines.

ATTY. TINA PEREZ

COUNSEL FOR RESPONDENT

14B Rufino Pacific Tower,

Ayala Avenue, Makati City

VERIFICATION/CERTIFICATION

I, JUANITA DE LA CRUZ, of legal age, married, Filipino and resident of 2111

Cityland Megaplaza, Ortigas Center, Pasig City, after having been duly sworn to in
accordance with law, do hereby depose and say that I caused the preparation of the
foregoing answer and that the contents thereof are understood by me after being
translated in the dialect I understand and that the same are true to my own knowledge and
belief and based on authentic records.
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 therein; and that if ever I should thereafter learn that the
same or similar action has been filed or is pending, I shall report such fact within five (5)
days therefrom to this Honorable Court.

IN WITNESS WHEREOF, I have hereunto affixed my signature this 15th day of

February at Manila, Philippines.

JUANITA DE LA CRUZ
Affiant

Copy furnished:

ATTY. ELVIS PRESLEY

COUNSEL FOR PETITIONER

366 Rufino Pacific Tower,

Ayala Avenue, Makati City

EXPLANATION: Copy furnished by registered mail due to distance, time constraint

and lack of office personnel to effect personal service.