REPUBLIC OF THE PHILIPPINES REGIONAL TRIAL COURT Tenth Judicial Region Branch 7 Bayugan City, Agusan del Sur

BEATRIZ CAMPOS-LONGAQUIT Petitioner. Civil Case No. 0001-2013-A -versusFor: DECLARATION OF NULLITY OF MARRIAGE

DANIEL LONGAQUIT Respondent. x ---------------------------------------------/

ANSWER
COMES NOW, the respondent through the undersigned counsel unto this Honorable Court most respectfully submits his answer and avers that:

THE PARTIES 1. Petitioner Beatriz Campos-Longaquit, is of legal age, married to respondent, Filipino citizen and with present residence address at Miapis St., Bedcor, Brgy. Poblacion, Bayugan City, Agusan del Sur. 2. Respondent Daniel Longaquit, is of legal age, married to petitioner, a Filipino citizen, with residence address at P-5, Poblacion, Sibagat, Agusan Del Sur, where he may be served with notices and other processes; 3. This answer is made by the respondent for the purpose of denying the allegations of the petitioner and show the court his dissent to the annulment of their marriage; 4. Respondent firmly believes that their marriage problems can be solved by means other than this proceeding. 5. The following are the facts and events showing that the respondent does not suffer psychological incapacity;

NON-EXISTENCE OF PSYCHOLOGICAL INCAPACITY A. Respondents repeated marital infidelity (philanderer) 6. Respondent vehemently object to being labeled as a philanderer. His good looks and being caring is often misunderstood by several women. They tend to think that he feels something for them and consequently, rumors about an illicit affair would spread. 7. Miss Beatrice Campos-Longaquit, on the other hand, would easily believe those rumors which are utterly unsubstantiated. The alleged phone calls were nothing but an exaggeration. The individuals calling about his whereabouts were his friends. It is only because of the petitioners prejudice and unfounded jealousy that she could think that those are respondents flings or mistresses. 8. Respondent, in his heart and mind truly and faithfully adore the petitioner. It is but a big disgrace and irony that he would want a woman other than his wife. There could be no other woman who could be greater or even just equal the beauty and personality of his wife. B. Respondents cruelty and violence 9. Respondent would admit the he hit the petitioner once or twice during their marriage. But the same was neither repeated nor was it brutal. It was a mere slap in the face with a minimal amount of strength employed. 10. Respondent was only moved to do the same because of the continuous nagging of the petitioner. It is her unfounded jealousy again which prompted her to hurl several accusations against the respondent. 11. Respondent, as a man of God, truly believes that a woman is a being worthy of respect and care. Violence against women runs counter to his conviction and his faith. C. Respondents chronic refusal to maintain harmonious family relations and lack of interest in a normal married life and lack of support 12. This allegation is nothing but a complete falsity. Herein respondent loves his wife and children. He wanted to spend a lot of time with them. It is only because of respondent s studies and several jobs that he will sometimes be remiss in his responsibilities as a father and as a husband. But this neglect does not amount to a chronic refusal to maintain a harmonious family relation. It is a fallacious argument. 13. It is utterly false that he does not support his wife and children. This proposition is bereft of evidence. It is a settled rule that mere allegation is not tantamount proof. 14. Respondent believes that the family is the foundation of the nation and the basic social institution. It should at all times be cherished and protected. It should not be shattered by mere misunderstanding brought about by insecurities and unfounded jealousy. 15. We come to love not by finding the perfect person but by learning to see an imperfect person perfectly. 16. Respondent may have committed faults as a husband and as father but those were not enough to severe the relationship tied before our Supreme God. What God has joined together, let no one separate.

17. Respondent may have caused few bad memories, but petitioner must not forget the thousand good memories that they had together. Those times when every single moment spent together is like a dream come true. Thus, instead of thinking about separation, why not pursue the path to reconciliation.

PRAYER WHEREFORE PREMISES CONSIDERED, respondent most respectfully prays to this Honorable Court that the petition for the declaration of the nullity of marriage filed by BEATRICE CAMPOS-LONGAQUIT be dismissed. Respectfully submitted. Bayugan City, Philippines, this 6th day of December 2013.

ELICANO AND GASTARDO LAW FIRM Unit 2, 4th floor, XCZ Building Montilla Blvd, 8600 Butuan City Telefax: (085) 324-5637 By:

Atty. Leomil B. Gastardo Counsel for the Respondent IBP No. 79686574 12-19-2012 Butuan City PTR No. 88908768 01-03-2013 Butuan City TIN 546-833-876 Roll No. 1798578, Page No. 988, Book LXI MCLE No. 8958743 Dec. 6, 2012 Mobile No. 092134567811

VERIFICATION
I, Daniel Longaquit, of legal age, married to petitioner, a Filipino citizen, with residence address at P-5, Poblacion, Sibagat, Agusan Del Sur., under oath, depose and state; 1. I am the respondent in this case; 2. That I have caused the preparation of this pleading; 3. I have fully read and understood the same; 4. That the allegations contained therein are true and correct based on my personal knowledge and on authentic documents; TO THE TRUTH OF THE FOREGOING, I hereby set my hand this 6th day of December 2013 in Butuan City, Philippines.

DANIEL LONGAQUIT Respondent

SUBSCRIBED AND SWORN to before me this ___ day of __________ 200_ at _________________ affiant exhibiting to me his Community Tax Certificate No.____________________ issued on ________________ 200_ at ______________ City. Doc. No. ; Page No. ; Book No. ; Series of 200_.

Atty. Leomil B. Gastardo Notary Public Until December 31, 2013 IBP No. 79686574 12-19-2012 Butuan City PTR No. 88908768 01-03-2013 Butuan City TIN 546-833-876 Roll No. 1798578, Page No. 988, Book LXI MCLE No. 8958743 Dec. 6, 2012 Mobile No. 092134567811