REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT OF MANILA

BRANCH 123

MARGE SIMPSON
Petitioner, Civil Case No. 32145
For: Annulment of
Marriage and
-versus- Declaration of Nullity of
Marriage

HOMER SIMPSON
Respondent,
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ANSWER

COMES NOW, the defendant, through the undersigned counsel

and unto this Honorable Court, most respectfully avers:

1. Paragraph 1 of the petition ADMITTED.

2. Paragraph 2 of the petition ADMITTED.

3. Paragraph 3 of the petition with respect to the fact that they live
as a husband and wife is ADMITTED. It is however, DENIED
that during this time he manifests symptoms of psychological
incapacity to comply with his essential marital obligations such
as his failure to observe love, loyalty, respect, and responsibility
for the petitioner and their children.

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4. Paragraph 4 of the petition DENIED, the respondent during
their marriage is being responsible, caring, and loving husband
to his wife and a father to his children, in contrary it is the
petitioner who is the one being neglectful and irresponsible
during their marriage life because when petitioner and
respondent got married, petitioner always go to different bars
and go home late and drunk, and petitioner also hired a maid
that the respondent paid to clean and watch over the children
while she just sits all day in the couch to watch movies and
apply cosmetics all over her body, while respondent is at work.

5. Paragraph 5 of the petition with respect to the fact that during

their marriage life as husband and wife they had quarrels and
misunderstanding is ADMITTED. But DENIED that he
physically abused the petitioner and disharmony caused by
respondent’s emotional and intellectual immaturity,
irresponsibility, unfounded jealousy, unreasonableness, lack of
love, loyalty and respect, for which the petitioner was deprived
of peace of mind, happiness and tranquility which have resulted
to the nervous breakdown and tension of petitioner.

6. Paragraph 6 of the petition DENIED, respondent always make

sure that his family is doing fine and doing his best to provide
their needs for them to live a peaceful and happy life.

7. Paragraph 7 of the petition DENIED, respondent never

abandoned his three (3) children with the petitioner, last July
15, 2015 respondent left home to go Belgium for his job and not
to abandon the said children of his, because of the nature of his
work as an international public relations manager of Bounty
Agro Ventures, Inc. and a top performer in the company, he is

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 one of the chosen PR managers to go to Belgium as a delegate
to develop a marketing communication plans including strategy,
goals, budget and tactics, develop media relations strategy,
seeking high-level placements in print, broadcast and online
media, monitor, analyze and communicate PR results on a
quarterly basis of the newly established branch in such country,
while staying on Belgium he always sends money back to the
Philippines every month for the petitioner and his children, also
he always send text messages and emails to petitioner but
there are no text messages or emails being sent back to
respondent. He also calls their landline phone back home to
contact his family, but it’s always the answering machine or the
maid who answers the call and whenever being ask where is
the whereabouts of the petitioner the maid always says that
“petitioner is not at home” which is weird because petitioner is
just a plain housewife.

8. Paragraph 8 of the petition DENIED, petitioner do not have a

work and just at home putting make-ups and other cosmetic
products all day and if not putting cosmetics, petitioner is
always at the mall buying sexy dresses for her. The respondent
also sends money to petitioner for their daily needs and living,
and also send money to his mother as a payment for the
education of the respondent three (3) children who are studying
at a prestigious school in the country.
9. Paragraph 9 of the petition ADMITTED.

10. Paragraph 10 of the petition DENIED, respondent is not

psychologically incapacitated, therefore there were no cause of
action to annul the marriage under Article 36 of the Family
Code.

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 COUNTERCLAIM

11. Respondent reiterate and incorporates by reference all

the foregoing insofar as they are material and additionally
submit that he is entitled to relief arising from the filing of this
malicious and baseless suit, as follows:

a. Moral Damages amounting to One Million Pesos

(PHP1,000,000.00) because his name and reputation
were besmirched by this malicious and baseless suit.
b. Attorney’s Fees amounting to One Hundred Thousand
Pesos (P100,000.00) because he was compelled to
secure services of counsel to vindicate his legal rights.

PRAYER

WHEREFORE, Respondent respectfully prays that judgment be

rendered in his favor by dismissing the Petition for Annulment of
Marriage and Declaration of Nullity of Marriage filed against him for
lack of cause of action, and granting respondents counterclaim by
awarding respondent : (a) One Million Pesos as Moral Damages, and
(b) Fifty Thousand as Attorney’s Fees.

Petitioner likewise prays for such other and further relief or

reliefs as this Honorable Court may deem just and equitable in the
premises.

July 8, 2016

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ATTY. MELVIN B. MANZO
Counsel for Respondent
GMA Building, GMA Avenue, Manila
IBP No. 123456 dtd. 01-07-16 Manila
PTR No. 7654321 /01/14/16 Manila
Roll No. 54321
MCLE Compliance II - 0004321
Dtd. March 27, 2017

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