REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
PASAY CITY
Branch 20

IN THE MATTER OF THE

SOLE CUSTODY OF PRINCESS AURORA
PETITION NO.: M-123
QUEEN MALEFICENT
MOTHER OF PRINCESS AURORA
Petitioner.
X-----------------------------------------------------x

ANSWER
RESPONDENT, by counsel and unto this Honorable Court, most respectfully states and
alleges that:
1.

The Respondent admits the allegations in Paragraphs 1, 2, and 3, there being no reason to

deny it.
2.

Paragraph 4 is likewise admitted.

3.

Respondent vehemently denies the allegation in Par. 5 that, accordingly, even during the

pendency of the said petition for annulment, Respondent did not show any interest, love and care
over the said minor, AURORA, the truth being that the Respondent religiously visits the minor at
the house of the petitioner even during the pendency of the said petition for annulment. The
respondent even brings gifts and food for the minor every time he visits her.
4.

Paragraphs 6, 7 and 8 are vehemently denied, the truth being that the Respondent is

giving the petitioner a monthly allowance in the amount of P10, 000.00 for the finances of the
minors schooling and for her other basic needs.
5.

Paragraph 9 is specifically denied for lack of knowledge sufficient to form a belief as to

the truth thereof.

6.

Respondent strongly denies Paragraph 10, the truth being that the Respondent always

takes time to visit the minor at the house of the petitioner, especially during special occasions.

7.

Respondent admits Paragraph 11, but only insofar as to the fact that Respondent has

another live in partner and has a child with her, but strongly and specifically denies the rest of the
averments therein, the truth being that even if the Respondent has already another family, he
never fails to show his love, care and affection to his child with the petitioner, as already
mentioned in the preceding paragraph.
8.

Respondent strongly denies Paragraphs 12, 13, 14 and 15 for lack of knowledge

sufficient to form a belief as to the truth thereof.

9.

Respondent specifically denies Paragraphs 16, 17, 18 and 19 as to the allegation that hee

has no permanent work and is very much dependent only on his own parent for his own survival
and existence and that there is no clear showing that the Respondent has ways and means to
sustain the custody and care of the herein minor, the truth being that the Respondent is gainfully
employed as Assistant Supervisor in ALDUB Supermarket, as evidenced by his Certificate of
Employment and Identification Card issued by the Company. Copy of said Certificate of
Employment and ID is hereto attached as Annexes 1 and 2;
10.

Paragraph 20, 21, 22, 23, 24 and 25 are specifically denied for lack of knowledge

sufficient to form a belief as to the truth thereof;

11.

Respondent is morally and financial qualified to take care of over the person of minor

AURORA;
12. That the foregoing being considered and for the best interest of the minor, it is most
respectfully prayed that joint custody be issued over the care of the minor.
WHEREFORE, it is respectfully prayed of this Honorable Court that the foregoing
Answer be please given due course, and that joint custody over of the minor AURORA be given
to the Respondent.
Other measures of relief favorable to the Respondent are likewise prayed.
Pasay City, Metro Manila, July 30, 2015.

ATTY. ELIZABETH B. QUEDA

Counsel for Respondent
QTP AND ASSOCIATES LAW OFFICE

G/F Amber Gold Bldg.

18 Shaw Blvd., Pasig City
PTR No. 1249657 1.05.15 PTO Pasig
IBP No. 897640 1.05 Pasig Chapter
TIN No. 403-568-743;
MCLE NO. V 12345

VERIFICATION
I, KING ESTEFAN, after being sworn to, hereby depose and say: that I am the father of
the minor, Princess Aurora; that I caused the foregoing Answer to be prepared by my counsel;
and that the contents therein are true and correct of my own knowledge or based on authentic
records.
Pasig City, August 13, 2015.

KING STEFAN
Affiant

SUBSCRIBED AND SWORN to before me this 13th day of August 2015, in the City of
Pasig. The Affiant exhibited to me his SSS ID No. 1223456-6 issued on December 2, 2010 at
Pasig City, Philippines.

ATTY. CLARISSA TRAJE

Notary Public
Commission Expires December 31, 2015
PTR No. 1249657 1.05.15 PTO Pasig
IBP No. 897640 1.05 Pasig Chapter
TIN No. 403-568-743; Roll No. 56784

Doc. No.322;
Page No.53;
Rook No. 8;
Series of 2015.

COPY FURNISHED:
THE SOLICITOR GENERAL
134 Kaingin Street,
Pasay City

QUEEN MALEFICENT
#69 M. Donada Street,
Pasay City

served via registered mail

with return card

by personal service