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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

NATIONAL CAPITAL JUDICIAL REGION

SAN JUAN CITY, MANILA

BRANCH 69

MIA D. SOLITO,
Civil Case No. ___________
Petitioner,
(for: Declaration of Nullity of
Marriage.

Annulment of Marriage)
- versus -

EDLANO KRISTAN S. SOLITO,

Respondent.

x------------------------------------x

ANSWER

Respondent, EDLANO KRISTAN S. SOLITO, through the


undersigned counsel, and unto this Honorable Court, most
respectfully avers the following in response to the Petition for
Declaration of Nullity.

1. 2 is admitted insofar as his personal circumstances are


concerned.

2. 4 is DENIED, the truth of the matter being that:

2.1. No phone call was made between Mrs. Solito and Mr.
Darisan, a copy of the service providers records is
hereto attached as Annex A
2.2. No company party was held at Bedrock Bar on January
31, 2016, a copy of the sworn statement by Ms.
Kristine N. Pomasin, Bedrock Bars manager is hereto
attached as Annex B

2.3. Mr. Edlano Kristan S. Solito, during the alleged time


of infidelity and contractment of HIV, was not in the
Philippines as he was working overseas, a copy of the
sworn statement by Ms. Karen Mae N. Tayo is hereto
attached as Annex C and a copy of supporting
document from Bureau of Immigration is hereto
attached as Annex D

3. 5 is DENIED insofar as the Respondents supposed act


of doing immoral acts with another woman such as kissing
intensely is concerned, a copy of the sworn statement of a
fraud analyst is hereto attached as Annex E

4. 6 is DENIED insofar as the alleged incident and


reconciliation between Mrs. Mia D. Solito and Mr. Edlano
Kristan S. Solito.

5. 7 is DENIED insofar as the failure to uphold the alleged


promise and the allaged claim that Mr. Edlano Kristan S.
Solito arrives late.

6. 8 is DENIED insofar as the confession having been stated


in bad faith, a copy of the sworn statement by Mrs. Reina
Mae S. Garcia is hereto attached as Annex F

7. 9 is DENIED, the truth of the matter being that the


subject of the argument is not about the affair but future
plans to have kids.

8. 12 is DENIED, the truth being that that the affair


commenced during the pre-marital relationship between
Mrs. Mia D. Solito and Mr. Edlano Kristan S. Solito.
9. 12 is DENIED insofar as Mr. Edlano Kristan S. Solito
being HIV positive, a copy of the medical records is hereto
attached as Annex G.

PRAYER

WHEREFORE, it is respectfully prayed of the Honorable


Court that after due notice and hearing, judgment be issued:

1. Dismissing the petition for the declaration of nullity of


arriage between respondent and petitioner for failure to
show proof that it is null and void under Article 36 of the
Family Code;

Petitioner further prays for other reliefs as may be deemed


just and equitable under the premises.

San Juan City, October 25, 2016.

ATTY. NEIL DON M. ORILLANEDA

Counsel for the Respondent

Unit 202-4 PYF Building

G. Apacible St., Malate, Manila

PTR No. 203281/Manila City/Jan 2, 2014

IBP No. 783201/Manila City/Oct. 14, 2014

Roll No. 76301

MCLE Compliance No. X-000261/Jan. 13, 2015

Tel No. (02) 405-6327

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