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    Annulment - Reply

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    Carmelito Dante Clabisellas
    This document is a reply filed in a civil case for nullity of marriage. It summarizes the plaintiff's responses to the defendant's answer. The plaintiff denies the defendant's claims that she initiated sexual intercourse and disputes that a push was minor given the scar on her head. The plaintiff also argues the defendant's narcissistic personality disorder is grounds to prevent him from complying with marital obligations. Finally, the plaintiff asserts the defendant incorrectly alleged a failure to state a cause of action.

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    Annulment - Reply

    Uploaded by

    Carmelito Dante Clabisellas
    135 views3 pages
    This document is a reply filed in a civil case for nullity of marriage. It summarizes the plaintiff's responses to the defendant's answer. The plaintiff denies the defendant's claims that she initiated sexual intercourse and disputes that a push was minor given the scar on her head. The plaintiff also argues the defendant's narcissistic personality disorder is grounds to prevent him from complying with marital obligations. Finally, the plaintiff asserts the defendant incorrectly alleged a failure to state a cause of action.

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    ANNULMENT - REPLY sample

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    3. ANNULMENT - REPLY

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    This document is a reply filed in a civil case for nullity of marriage. It summarizes the plaintiff's responses to the defendant's answer. The plaintiff denies the defendant's claims that she initiated sexual intercourse and disputes that a push was minor given the scar on her head. The plaintiff also argues the defendant's narcissistic personality disorder is grounds to prevent him from complying with marital obligations. Finally, the plaintiff asserts the defendant incorrectly alleged a failure to state a cause of action.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    135 views3 pages

    Annulment - Reply

    Uploaded by

    Carmelito Dante Clabisellas
    This document is a reply filed in a civil case for nullity of marriage. It summarizes the plaintiff's responses to the defendant's answer. The plaintiff denies the defendant's claims that she initiated sexual intercourse and disputes that a push was minor given the scar on her head. The plaintiff also argues the defendant's narcissistic personality disorder is grounds to prevent him from complying with marital obligations. Finally, the plaintiff asserts the defendant incorrectly alleged a failure to state a cause of action.

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    © All Rights Reserved
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    Download as docx, pdf, or txt
    of 3

    REPUBLIC OF THE PHILIPPINES

    REGIONAL TRIAL COURT


    7TH Judicial Region
    Talisay City, Cebu
    Branch 10

    Ms. TMG
    Petitioner,

    -versus- CIVIL CASE NO. TCV-2017-143

    FOR:
    Mr. MPG Declaration of Nullity of Marriage
    Respondent.
    x-------------------------------------------x

    REPLY

    PLAINTIFF, herein represented by her Attorney-in-fact, ---, thru the


    undersigned Counsel, unto this Honorable Court, most respectfully submits
    this Reply to Defendant’s Answer, thus avers that:

    1. Defendant, in paragraphs 2 allege that it is always the Petitioner who


    asks to have sexual intercourse. Such allegation is not true considering
    that she is a pious woman.
    2. Defendant, in paragraphs 3 allege that he loves the Petitioner and their
    child but such allegation has no basis.
    3. Defendant, in paragraph 4 allege that it is always her who initiates
    their sexual intercourse, however that same allegation is not true since
    she considers herself as again a pious woman who firmly believes that
    it should be the husband who should initiate.
    4. Defendant, in paragraph 6 the defendant allege that it was a slight
    push, however the scar in my head would clearly show that it was not
    a slight push.
    5. Defendant, in paragraph 6 the defendant allege that it was a slight
    push, however the scar in my head would clearly show that it was not
    a slight push.
    6. Defendant, in paragraph 7 allege that the Respondent DENIES that
    Narcissistic Personality Disorder is grave enough to prevent him from
    complying with the essential marital obligations, however, This
    condition was ingrained from Felipe's "poor parental and family
    molding," which caused him to "develop a defective superego and
    gross disregard for the feelings of others, particularly his wife
    7. Defendant, in paragraph 8 alleges the failure to state cause of action,
    such allegation is not correct for the reason that all elements of cause
    of action are present.
    WHEREFORE, premises considered, it is hereby respectfully
    prayed that the foregoing Reply to Defendant’s Answer be given due
    credence and consideration and the reliefs prayed for in the Complaint be
    granted.

    Finally, Plaintiff respectfully prays for such and other reliefs as may
    be deemed just and equitable under the premises.

    February 15, 2019, Cebu City Philippines.

    Counsel for the Plaintiff

    ATTY. MENCHELL RALPH MARGALLO


    PTR No. 1234567 1-5-2012
    IBP No. 987243 2-21-11
    MCLE Compliance No. III-000123
    ROLL NO. 31097 7-10-98

    COPY FURNISHED:

    CLABISELLAS & ASSOCIATES


    Attn: Atty. Carmelito Clabisellas Jr.
    14th Floor Philamlife Tower
    APAS, Cebu City

    OFFICE OF THE SOLICITOR GENERAL

    Makati City

    EXPLANATION

    Complainant serves the copy of the foregoing Reply via


    registered mail due to lack of office personnel.
    ATTY. MENCHELL RALPH MARGALLO

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