REPUBLIC OF THE PHILIPPINES

Sixth Judicial Region

Regional Trial Court
Branch___________
CJ Ramon Q. Avancena Hall of Justice
Iloilo City
LEOUEL SANTOS,
Petitioner,

Civil Case No.___________

Vs.

For: Annulment of Marriage

JULIA ROSARIO BEDIA-SANTOS,

Respondent

x----------------------------------------------x
ANSWER
COMES NOW, the defendant by the undersigned counsel, respectfully alleges that:
1. Defendant admits that portions of par.1-8 of the complaint regarding the names,
residences, status of the parties, and the prayer stated in the petition but denies
that she is psychologically incapacitated as regard to her marriage with petitioner.
2. Defendant denies under oath that she failed in her marital obligations with the
petitioner but instead, avers that it is the petitioner alone who is psychologically
incapacitated.
3. That defendant has persistently demanded that petitioner and her should live
independently both physically and financially from their parents but her pleas were
met on deaf ears.
4. That Petitioner Leouel spent weeks at a time with his parents, without even
communication with the defendant.
5. That Leouel didnt even contribute to the pre-natal and the delivery of their child
Leouel Jr. Santos.
6. That Leouel spent his wages as a soldier, drinking and roaming around the
province of Iloilo during much of his free time.
7. That the Defendant, Julia Rosario Bedia- Santos tried to patch up her marriage
with petitioner Leouel Santos through the assistance of Dr. Ma. Lourdes Go, a
psychiatrist from November 11,1986 up to the time she left for the United States of
America on January 1,1989. Attached hereto as Annex A are the psychological
sessions attended to by Julia Bedia-Santos and her husband Leouel Santos starting
from November 11, 1986 up to November 11, 1987.

8. That the psychological therapy session undergone by the couple proved to be of

no avail in helping Leoel comply with his marital obligations.
9. That on November 21, 1987, Dr. Ma. Lourdes Go had suspicions that her patient
Leouel Santos was psychologically incapacitated to perform his marital obligations.
The psychiatrist asked Julia Bedia-Santos and her husband Leouel Santos,
permission to conduct a series of confidential examinations to learn more of
Leouels interest so as to better diagnose their problem. Julia and Leouel consented
that the findings are to be made confidential. Attached thereto is the medical
contract signed by Dr. Go and the Santos Spouses as Annex B.
10. After 9 months of further diagnosis and therapy Dr. Ma. Lourdes Go fully
determined that Leouel Santos is burdened with Shcnauber Schizophrenia, a mild
but permanent and incurable form of schizophrenia that disables Leouel to comply
with his marital obligations. Attached thereto are the clinical findings and research
made by Dr. Ma. Lourdes Go on August 14, 1986 as Annexed C.
11. That from that time on Julia Bedia- Santos was distraught. She sought
employment abroad as a subterfuge over the crisis with her marriage to Leouel
Santos.
12. That on January 1,1988, she went to the United States to seek employment and
to save up money to have her marriage with Leouel annulled due to his
psychological incapacity.
PRAYER
Wherefore, premises considered, it is respectfully prayed that the marriage of the
parties be declared null and void from the beginning under Article 36 of the Family
Code.
Petitioner also prays for other reliefs as may be deemed just and equitable under
the premises.
Iloilo City Philippines, 08 December 2015

Atty. Petri John L. Doronila

Lead Counsel for the Defendant
MacDo Law Office
Unit 1, X Building Recto Manila
IBP No. 123456;01/10/10-Manila
Ptr No.1234567;01/10/10-Manila
Roll No. 12345;5/05/05
MCLE No. 1-001234;9/09/15
Atty. Ace Macalalag
Counsel for the Defendant
Co-Counsel for the Defendant
MacDo Law Office

Unit 1, X Building Recto Manila

IBP No. 123456;01/10/10-Manila
Ptr No.1234567;01/10/10-Manila
Roll No. 12345;5/05/05
MCLE No. 1-001234;9/09/15
VERIFICATION AND CERTIFICATION AGAINST FORUM SHOPPING
I, Julia Rosario Bedia-Santos, Filipino of legal age, married, and a resident of La Paz,
Iloilo City, after having been sworn to in accordance with law, hereby depose and
say:
1. That I have caused the preparation of the foregoing petition;
2. That I have read the allegations and contents thereof and the same are true and
correct based on my personal knowledge and based on authentic records;
3. I hereby certify that I have not heretofore commenced any action or filed any
claim involving the same issues in any court, tribunal, or quasi-judicial agency.
If I should hereafter learn that any other similar action or claim has been filed or is
pending, I shall report that fact within 5 days from knowledge thereof to this
Honorable Court.
IN WITNESS WHEREOF, I have hereunto set my hand this 8 th Day of December in
Iloilo City, Philippines

Julia Rosario Bedia-Santos

JURAT
Copy furnished:

Atty. Donna Fresnido

Lead Counsel
23 Jambalaya St, Leganes, Iloilo.
IBP No. 123456;01/10/10-Iloilo
Ptr No.1234567;01/10/10-Iloilo
Roll No. 12345;5/05/05
MCLE No. 1-001234;9/09/15

Republic of the Philippines)

City of Manila

) S.S

AFFIDAVIT OF SERVICE
I, Juan Dela Cruz, under oath declare that:
1. I am the messenger of Att. Ace Macalalag, counsel for the defendant, Julia
Rosario Bedia-Santos in the case entitled Leouel Santos vs. Julia Rosario BediaSantos in Civil Case No________, and that as such messenger I served upon the
counsel of adverse party, the pleading filed in said case as follows:
(for personal service) Atty. Donna Fresnido, Lead Counsel for the petitioner,
Leouel Santos, by delivering personally a copy of said pleading upon said lawyer
who acknowledged receipt therof as shown by her signature or initial on the said
pleading, this 9th Day of December 2015.
IN WITNESS WHEREOF, I have hereunto affixed my signature this 9 th Day of
December 2015 in the City of Iloilo.

Juan Dela Cruz

JURAT
SUBSCRIBED AND SWORN to before me this 9th day of January, 2015 at Iloilo
City, Affiant exhibiting to me his drivers license bearing No.N11-82-320583 expiring
on 10/10/2015

ATTY. BREWSKY DORONILA

Unit 1, X Building Recto Manila
IBP No. 123456;01/10/10-Manila
Ptr No.1234567;01/10/10-Manila
Roll No. 12345;5/05/05
MCLE No. 1-001234;9/09/15
Doc No.1;

Page No.2;
Book No.1;
Series of 2015;