REPUBLIC OF THE PHILIPPINES REGIONAL TRIAL COURT BRANCH_____ ECHAGUE, ISABELA

ANDREW F. SANTOS PETITIONER CIVIL CASE NO: 3005 FOR: FOR DECLARATION NULLITY OF MARRIAGE

-versus-

OF

SHEENA R. ACOSTA-SANTOS RESPONDENT X-------------------------------------------------------------X

ANSWER
RESPONDENT, by and through the undersigned counsel, unto this Honorable Court, respectfully states: 1. Respondent is a Filipino citizen, of legal age, married and a resident of Purok 01, Barangay Rosario, Santiago City, Philippines, where he may be served with summons as well as the other court orders and process. 2. Respondent admits that the foregoing circumstances referred to in paragraph 2 and 3 is true to the best of her knowledge. 3. Given the eight(8 )years of being a lover is enough year and reason to decide whether or not I will agree on the marriage proposal offered to me by the Petitioner but the allegation pertaining to the marriage insinuated by father is just a mere suggestion doesnt need to be materialize. 4. Given that I am his housewife, earlier in our married life I observed some changes in the attitude of the petitioner and soon his failure to perform the lawfully ordained duty of a spouse to me. Some changes is 5. Defendant likewise admits that after their wedding they settled in San Fanbian, Echague, Isabela which Andrew obtained through HDMF housing loan. That Im contented that of whatever amount her husband gave her out of his salary because his salary because I know he had to pay the monthly salary of her own. I tried my best to cope up with their needs and not to initiate anything that would cause her husband raise his temper. 6. After settling in San Fanbian, Echague, Isabela, more changes that I observed in the character of the herein petitioner. Some of which are, petitioner shouted when he is angry, he did not like to be talked when tired. He was very meticulous in the orderliness of his things. He did not like his belongings to be touched or rearranged. 7. Almost three years of being married but still they dont have a child; they decided to consult a doctor. Both of them were on medication. For petitioner for low

sperm count and respondent for hormonal imbalance. Both wanted a child. Petitioner being an only son was expected to extend the Santos Family tree, 8. In the year 2005, respondent decided to quit her job with the thought that both her work and absence in their house when her husband was on the vacation could also be hindrance to her being impregnated. Their efforts to have a child prove futile. Being bored housewife, respondent engage into a direct selling like Marikina Shoe Exchange products, Boardwalk, Natasha and Tupperware. But respondent failed. 9. Respondent further admit, that in the year 2007 their marital conflict was aggravated when respondent discovered a picture of woman and a bikini panty in her husbands bag, and she likewise discovered a monthly remittance slips to the woman. That ensued a quarrel and from that time on, he did not dare touch her nor had any sexual contact. At first they sleep together in one but petitioner complained of being disturbed in his sleep even with her slightest cough. From then on, respondent to another room. On weekends, he has always out during the day and came home late night. At times he missed to go home for two or three days because of his car racing activities where he consumed most of his free time and money. 10. Respondent decided to open a canteen at ISU junction, Echague, Isabela in the years 2008. Petitioner gave her amount of fifty thousand pesos (P 50, 000) to start the business but the proceed of the said amount is for refrigerator and kitchen utensils and table wares. Her parents and some of her relatives help in building the canteen but again it is failed. At this moment the couple stated to have an argument since they started to go home late and the petitioner go home late at night and found out there was no food for him. His regular weekends as vacation days were reduced to two days in a month. 11. Although respondent got boring she never indulged herself to majhong to escape her boredom. Until one day both of them got stranger and one time the petitioner told the respondent to get her things because he will lock the house. 12. Immediately after their marriage, the first thing that the respondent observed at the earlier part of their marriage becomes worst and a clear manifestation of his mental or psychological incapacity which leads to his failure to perform his lawfully ordained duty of a spouse.

PRAYER
WHEREFORE, premises considered, it is hereby prayed, that after hearing, judgment be rendered ordering the following: 1. Declare the marriage of respondent to petitioner null and void in accordance with article 36 of the family code. 2. Ordering the petitioner to pay the respondent the following: a. Five hundred thousand pesos (P 500, 000) as moral damages b. To pay the cost and expenses for attorneys fees for litigation