REPUBLIC OF THE PHILIPPINES

NATIONAL JUDICIAL CAPITAL REGION

REGIONAL TRIAL COURT
Pasay City
Branch 108

CATALINO “LINO” BARTOLOME

Petitioner,

CIVIL CASE NO. RTC-PSY-1022-16

-versus- FOR: Declaration of Nullity
of Marriage

JADE FLORES-BARTOLOME
Respondent.
x---------------------------------------------x

ANSWER

COMES NOW, the Respondent, JADE FLORES-BARTOLOME, through

the undersigned counsel and unto this most Honorable Court, hereby
depose and state, that:
I
ADMISSIONS

1. The personal circumstances of the Petitioner and of the Respondent

as provided by paragraphs 1 and 2 of the instant Petition are hereby
admitted;

2. That paragraphs 5, 6, 7, 8, 9, 10, 16, and 30 of the instant Petition are

hereby admitted;

3. That the marriage between the Petitioner and of the Respondent

pleaded in paragraph 15 of the instant Petition is hereby admitted;
and

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4. That no property belonging to the community of property as pleaded
in paragraph 29 of the instant Petition is hereby admitted;

II
SPECIFIC DENIALS and NEGATIVE DEFENSES

5. The Respondent specifically deny the following allegations in the

instant Petition;

a) Paragraph 4 of the instant Petition is hereby PARTIALLY

DENIED as to the activities of the Petitioner in dealing in
automotive parts, went to a car expo in Pasay, Manila in the
hopes of scouting suppliers for his burgeoning auto parts retail
business for lack of sufficient knowledge to form a belief as to
the truth or falsity of such allegation, but as to the date when
the Respondent met the Petitioner is hereby admitted;

b) That the allegations in Paragraph 11 of the instant Petition are

hereby VEHEMENTLY DENIED as the allegations therein are
only lies and purely fictional statements of the Petitioner. The
Respondent is a woman with principles and dignity in life. She
can never be easily seduced by someone who she just met
somewhere. She is a very loyal woman in a way that she is
always making it appear to be proud for having the Petitioner
as boyfriend in her life;

c) That the allegations in Paragraph 12 of the instant Petition are

hereby VEHEMENTLY DENIED as the allegations therein are
only lies and purely fictional statements of the Petitioner. The
truth is that when the Respondent came back from Cebu, she
excitedly and more desire to see the Petitioner than her family.
In fact, if there was a change on the part of the Respondent, it is
her love to the Petitioner that became more intimate and
romantic during those times;

d) That the allegations in Paragraph 13 of the instant Petition are

hereby VEHEMENTLY DENIED as the allegations therein are
only lies and purely fictional statements of the Petitioner. The
truth of which is that on February 14, 2015, I was in Taiwan for

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 a vacation. To prove the same, the copy of the Passport of the
Respondent is hereby attached, made integral part of this
Answer, and marked as ANNEX “1”, bracketing the date of
departure “February 13, 2015” and date of arrival “February
20, 2015 as ANNEXES “1-A” and “1-B”, respectively;

e) That the allegations in Paragraph 14 of the instant Petition are

likewise DENIED as the allegations therein are only lies and
purely fictional statements of the Petitioner for being allegedly
consequences of the allegations in paragraph 13 that are
specifically denied;

f) That the allegation in paragraph 17 of the instant Petition as to

the Petitioner and Respondent who lived in blissful union as
Lino worked in his auto parts retail shop while Jade tended the
house is hereby admitted but as to the remaining is hereby
DENIED. The truth of which is that during weekends of those
times, the Respondent was, in fact, performing her marital
obligation as wife of the Petitioner such as doing laundry,
cleaning our house, cooking our meals and other household
activities. These acts of the Respondent were not only
performed during weekends but also during weekdays as she
was not yet employed;

g) The allegation pleaded in paragraph 18 of the instant Petition

as to getting employment on the part of the Respondent is
hereby admitted but as to the remaining are hereby DENIED as
the Respondent is, most of the time, coming home early or on
time. If the Respondent came home lately, it is for the
employment reason that her performance to render work is
required;

h) The allegation pleaded in paragraph 19 of the instant Petition is

hereby DENIED for lack of sufficient knowledge to form a belief
as to the truth or falsity of such allegation;

i) The allegation pleaded in paragraph 20 of the instant Petition is

hereby DENIED. In fact, the Respondent has no care to her
phone as she has no need to hide to the Petitioner. It is only the

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 Petitioner that made his own speculations that I have an extra-
marital affairs but this thing is not true;

j) The allegation pleaded in paragraph 21 of the instant Petition is

hereby DENIED. The Respondent did not make any such
prohibition to the Petitioner. In fact, it is not problematic on the
part of the Respondent if her phone was using by the Petitioner;

k) The allegation pleaded in paragraph 22 of the instant Petition is

hereby DENIED. The truth of which is that, I was always in our
house in Paco and the Petitioner’s allegation that I am out even
during weekends are only lies and purely fictional statements
of the Petitioner, but the allegation as to having no sexual life
with the Petitioner is hereby admitted but the reason is on the
Petitioner as he is the one who was out most of the time and
busy on his work;

l) The allegation pleaded in paragraph 23 of the instant Petition is

hereby admitted for the reason of the Respondent’s
employment but still, even if the former’s attention was on her
employment, she tried to help as much as possible in household
chores;

m) The allegation pleaded in paragraph 24 of the instant Petition is

hereby DENIED for lack of sufficient knowledge to form a belief
as to the truth or falsity of such allegation;

n) The allegation pleaded in paragraph 25 of the instant Petition is

hereby VEHEMENTLY DENIED. The truth of which is that the
Respondent never went to ACE Automotive. It is impossible on
the part of the Respondent to do such immoral things as she is
loyal, loving and equipped with high standards of dignity; and

o) The allegation pleaded in paragraph 26 of the instant Petition is

hereby DENIED for lack of sufficient knowledge to form a belief
as to the truth or falsity of such allegation;

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 PRAYER

WHEREFORE, premises considered, the Respondent respectfully asks

from this Honorable Court, after trial on the merits, to render judgment
dismissing the instant Petition for lack of merit.

Other reliefs, just and equitable, are also prayed for.

Quezon City for Pasay City, Metro Manila. July 20, 2016.

VELASCO LAW OFFICE

Counsel for the Respondent
Room 501, Victoria Tower 1,
Timog Avenue, Diliman, Quezon City
Contact No.: (02) 687 1112
E-mail: velascolawoffice@gmail.com

ATTY. JOSE LEOZAR VELASCO

Roll of Attorneys No. 47841
PTR No. 566871 / 01.09.16/ Quezon
City,
IBP No. 874112/ 01.09.16 (for 2016) /
Quezon City
MCLE Compliance No. V-547841
Dated 04/12/2016 / Pasig City

Copy Furnished (By Registered Mail):

CATALINO “LINO” BARTOLOME

Petitioner
142 Juan Luna St.,
Pasay City, Metro Manila

OFFICE OF THE
SOLICITOR GENERAL
134 Amorsolo St., Legaspi Village,
Makati City

5
OFFICE OF THE CITY
PROSECUTOR OF PASAY CITY
Through: SACP JUNJUN SANTIAGO
Hall of Justice, Pasay City Hall Compound
Pasay City, Metro Manila

EXPLANATION

Pursuant to Section 11, Rule 13 of the 1997 Rules of Civil

Procedure, undersigned counsel informs this Honorable Court that
personal service of Answer is not practicable due to unavailability of
messengerial personnel. Hence, it is being served by registered mail.

Atty. ATTY. JOSE LEOZAR VELASCO

6
Republic of the Philippines )
Pasay City, Metro Manila ) S.S.

VERIFICATION
I, JADE FLORES-BARTOLOME, Filipino, of legal age, and residing at
148 Brgy. Tandang Sora, Quezon City, Metro Manila, after being duly sworn
in accordance with law, hereby depose and state:

1. I am the Respondent in the above- entitled case;

2. I have caused the preparation and filing of the foregoing

Answer; and

3. I attest that the allegations therein contained are true and

correct of my own personal knowledge and based on authentic
records;

IN WITNESS WHEREOF, I hereunto set our hands this 20th day of

July, 2016 in Quezon City, Metro Manila, Philippines.

JADE FLORES-BARTOLOME
Affiant

SUBSCRIBED AND SWORN to before me this 20th day of July, 2016 in

Quezon City, Metro Manila, Philippines. Affiant exhibited to me her
competent evidence of identity, to wit: Philippine Passport No.
C07451AS24, issued on 2015 Sep 11 valid until 2020 Sep 10.

Atty. REDJINA ERICA CASTRO

NOTARY PUBLIC For Quezon City
Valid until December 31, 2017
Notarial Commission No. NC-11-2016
Roll of Attorneys No. 55474
IBP Lifetime Membership No. 12475/
01.15.15 / Quezon City
MCLE Compliance No. IV-145741
Doc. No 5; Dated 04/12/2016 / Pasig City
Page No. 2;
Book No. 3;
Series of 2016.