Republic of the Philippines

REGIONAL TRIAL COURT

National Capital Judicial Region
Branch 97 Quezon City

Manuel T. Rivera,
Petitioner,

CIVIL CASE NO. 36745

-versus-
FOR: ANNULMENT OF MARRIAGE

Eliza C. Rivera,
Respondent,
x-------------------------------------------x

ANSWER

The RESPONDENT, through counsel, and to the Honorable Court, most

respectfully avers that:

ADMISSION AND DENIALS

1. She admits the information in paragraphs 1, 2, 3, 4, 5, 6, 7, 15, and 16

2. She denies all the allegations in paragraphs 8, 9, 10, 11, 12, 13, 14, 17, 18,
and 19.

DEFENSES
3. Contrary to the allegations in paragraphs 8 and 9, Petitioner respected the decision
of Respondent not to have sexual intercourse on their first night as husband and wife and
to the succeeding months. Respondent, having no previous experience was nervous and
afraid to have sexual intercourse. Petitioner fully understood this predicament and agreed
to wait until the Respondent was ready. It took Respondent four months to overcome her
fear and finally agreed to have sexual intercourse with the Petitioner.
4. As to paragraph 10, Respondent who was adjusting to the newly married life and
to the experience of having sexual intercourse, tried her best to accommodate petitioner’s
desire and to fulfill her marital obligations.
5. The allegation in paragraph 11 is a great insult to the Respondent. One should not
compare their marriage life to others. The frequency of sexual intercourse in a marriage
does not define the success of the relationship. Moreover, based on the Petitioner, he saw
the respondent as a worthy companion for life. He had accepted their situation despite
the lack of sexual intercourse.
6. Denies the allegations in paragraphs 12 and 13. Respondent has no romantic
relations with Riza M. Villanueva, a co-workmate. Respondent and Riza are just close
friends. Petitioner must have interpreted their closeness in a malicious manner. Also,
assuming that they were in an illicit relationship, no one in their right mind would display
their affair in public more especially in their workplace where everyone knows that
respondent and petitioner are married. Moreover, respondent denies that she admitted
to petitioner that she is a lesbian.

PRAYER
WHEREFORE, it is respectfully prayed to the Honorable Court that after due
notice and hearing, judgment be rendered dismissing the petition for annulling the
marriage between Petitioner, Manuel T. Rivera, and Respondent, Eliza C. Rivera for
failure to show that there was concealment of lesbianism at the time of marriage under
paragraph 3 of Article 45 in relation to paragraph 4 of Article 46 of the Family Code.
Other reliefs, just and equitable under the circumstances, are likewise prayed for.

24 May 2022
Manila City

ATTY. DAN JOSEPH CALDO

Counsel for Respondent

SGD. ELIZA RIVERA

Respondent
 PROOF OF SERVICE
I, Atty. Dan Joseph Caldo, herein counsel for Defendant Eliza C. Rivera, hereby
certify that I personally delivered Defendant’s Answer dated 24 May 2022, to Plaintiff
Manuel T. Rivera, with address at 10A Pres. Garcia St., Teoville East Subd., Brgy.
Manresa, Quezon City, Metro Manila. The Answer was received by plaintiff himself.

ATTY. DAN JOSEPH CALDO

Counsel for Respondent

REPUBLIC OF THE PHILIPPINES

SUBSCRIBED AND SWORN TO before me on May 20, 2022 in Quezon

City, affiant exhibiting to me his competent evidence of identity, to wit: Passport-
issued on 25 April 2017 and valid until 24 April 2027.

Doc No. ; 014

Page No. ; 01
Book No. ; 001
Series of 2022.