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Republic of the Philippines

Regional Trial Court


7th Judicial Region
Cebu City
Branch ___

BOGART, Plaintiff CIVIL CASE NO. ______


FOR: Legal Separation
- versus -

GRACIA, Defendant
x---------------------------------------x

ANSWER

COMES NOW the Defendant, through undersigned counsel, unto


this Honorable Court, most respectfully states that:

1. Paragraphs 1, 2, 3 and 16 of the Complaint are admitted;

2. Paragraphs 4, 5, 8, 9, 12, and 13 are denied for lack of


knowledge or information sufficient to form a belief as to the
veracity or falsity thereof, the allegations therein being matters
known only to and are within the control of the plaintiff;

3. Defendant specifically denies the allegations contained in


Paragraphs six (6) and seven (7) of the Complaint, the truth of
the matter being those contained in the Affirmative Defenses
stated below;

4. Paragraphs ten (10) and eleven (11) of the Complaint are denied
insofar as it alleges the relationship between defendant and the
manager of Superstar Sports Bar, JERRY, the truth of the matter
being those contained in the Affirmative Defenses herein
below;

5. Paragraphs fourteen (14) is likewise denied insofar as it alleges


that BOGART and DANTE were just talking inside a room in the
Superstar Sports Bar, the truth being those alleged in the Affirmative
Defenses stated below;
AFFIRMATIVE DEFENSES

Defendant hereby reiterates the allegations contained in the


preceding paragraphs and further avers that:

1. Plaintiff has no valid cause of action against the defendant, the


allegations contained therein being purely based on hearsay,
speculations and, conjectures;

2. That the Defendant did not have an affair with DANTE. In fact, she
denies the existence of evidence attached in the Complaint as Annex
“B.” Such photos could have been photoshopped to ruin the
reputation of defendant as well as her marriage to Plaintiff; Commented [MC1]: HUHUHU IM NOT SURE WITH
THIIIIIISS!!! PORGIB MEH

3. Defendant knows DANTE because he was the vocalist of the


acoustic band that was playing during one of the parties she
attended;

4. It was also during that party when Defendant met JUNO, the best
friend of DANTE. They became good friends, but no romantic
relationship existed between them; Commented [MC2]: I CANT THINK OF PROOF? HUHUHU

5. Defendant likewise denies having a romantic relationship with


JERRY, the manager of the Sports Bar where Plaintiff works;

6. The allegations made by Plaintiff in the Complaint as to their


relationship is purely based on speculations. Plaintiff is merely
overthinking because of his baseless suspicions;

7. The Defendant and JERRY are merely friends. In fact, it was him
who informed her about his husband’s adulterous relationship with
a part time vocalist; Commented [MC3]: HEHEHEH

8. This is the reason why Defendant decided to visit his husband in his
workplace and observe;

9. On February 14, 2018, Defendant decided to surprise his husband


and went to the Sports Bar, but instead she was surprised to see his
husband with DANTE in flagrante delicto in one of their trysts;

10.Enraged and out of jealousy, Defendant attacked Plaintiff which


nearly killed him. Commented [MC4]: She attac
WHEREFORE, PREMISES CONSIDERED, Defendant most
respectfully prays that the subject Complaint BE DISMISSED for utter lack
of merit.

Other relief just and equitable in the premises are likewise prayed for.

Cebu City, Philippines, this 23rd day of February, 2017.

ATTY. MICAH JONA A. PAN


Counsel for Petitioner
MC Law Firm, UC Banilad, Cebu City
Roll of Attorneys No. 0518995
IBP No. 0518995 Lifetime/Cebu City
MCLE No. 1234567
PTR No. 98765432 Commented [MC5]: BABS EDIT NA LUNGSTS THIS

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