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-versus-
WILSON SANTOS,
Respondent.
X------------------------------------------X
ANSWER WITH
SPECIAL AND AFFIRMATIVE
DEFENSES
Respondent,
WILSON
SANTOS,
through
the
undersigned counsel, unto this Honorable Court, most
respectfully manifests and avers, to wit:
TIMELINESS OF THE ANSWER
1.
Copy of the Summons dated 12th of January 2015
from this Honorable Court was received by Respondent
Wilson Santos (hereinafter referred to as Respondent for
brevity), last January 13, 2015, giving Respondent fifteen
(15) days after service to file his Answer;
2.
The filing of this Answer with Special and
Affirmative Defenses today, January 23, 2015, is therefore
deemed timely for all legal intents and purposes;
9.
Paragraphs 26, 27 and 28 are specifically and
vehemently denied except the fact that Petitioner and
Respondent were always rushing, busy and arguing;
10. Paragraphs 29 and 30 are specifically denied for
lack of information or knowledge sufficient to form a belief
as to the truth or falsity thereof;
11. Paragraph 31 is specifically and vehemently
denied, the truth being that Respondent gave all that he
could to provide for his familys needs;
12. Save for the fact that there were instances when
Respondent would go home late due to work, the rest of the
allegations in Paragraphs 32, 33, 34, 35, 36, 37, 38, 39 and
2
PRAYER
WHEREFORE, PREMISES CONSIDERED, Respondent
most respectfully prays that the Petition be DENIED.
Other relief and remedies, just and proper under the
premises are likewise prayed for.
Most respectfully submitted this 23 January 2015,
Bacolod City, Philippines.
EXPLANATION
Copy of the foregoing Answer was furnished to the
Office of the Solicitor General and the address of Petitioner
through registered mail only and not by personal service by
reason of lack of personnel to effect personal form of service
in the address of Petitioner and the prohibitive distance
between Bacolod and the City of Makati.
JUAN DELA CRUZ
-Verification Follows6