Answer (Caption and Title) Defendant thru counsel, and in answer to plaintiffs complaint, respectfully avers: 1.

That he admits paragraph 1, 2, 3, 4, 5, 6, 15, 16, 17 and 18 of the complaint; 2. That he is without knowledge or information to form a belief as to the truth of the averments made in paragraph 7,8,9,10,11 thereof; 3. That he DENIES specifically each and every material allegation made in the paragraphs below and alleges respectively as follows that: 12- That the plaintiff, before the complaint was filed, demonstrated disrespect in numerous occasions which triggered the defendant to make a decision to go back to Mindoro to buy breathing space and preserve oneself due to the effect of the aforementioned ground to his personal being; 13 - That in no time, the defendant was a deadbeat to his family- for the fact that he owns exclusively businesses such as stocks and shares from different companies- BPI, Tiongsan, SM Baguio and a jitney with a franchise route from Baguio City to Aurora Hill and vice versa; 14 That pertaining to all dealings of the defendant by virtue of its exclusiveness in nature as his sole property under his own discretion which was included in the marriage settlement and that the plaintiff is in every respect aware of it. Though was not successful for quite some time but the relationship of the parties (defendant and petitioner) did not deteriorate at any time. 4. And as AFFIRMATIVE DEFENSES, the defendant alleges: A. That he is NOT psychologically incapacitated, he was not remiss in performing his obligations to his family both as a spouse to petitioner and father to their children. The defendant made the following efforts to wit: i. on a daily basis text messages sent to the petitioner soliciting of their whereabouts; ii. monthly allowances transmitted via Mlhuiller Kwarta Padala courier; iii. BENECO debit direct from the defendants bank account as payment for the petitioners residence monthly city services. B. That defendants business did not took him away from his family. He did exert efforts to the best of his ability to remain in touch with them while he was away in Mindoro;

5. As COUNTERCLAIM against the plaintiff, the defendant alleges:

A. That the defendant reproduces paragraphs 19, 20 and 21 of the plaintiffs

complaint as follows: 19. Adolfo brought respondent to Dr. Natividad A. Dayan for a psychological assessment to determine benchmarks of current psychological functioning. As with all other attempts to help him, respondent resisted and did not continue with the clinical psychologists recommendation to undergo psychotherapy; 20. The respondent was diagnosed with an antisocial personality disorder with marked narcissistic features and aggressive sadistic and dependent features, is psychologically incapacitated to fulfill the essential obligations of marriage: to love, respect and render support for his spouse and children. A personality disorder is not curable as it is permanent and stable over time; 21. The said psychological defect or illness is grave, serious and incurable and existed before marriage, but became manifest only after the celebration, due to marital demands and stresses; B. That the aforesaid stated premises loaded above (19, 20, and 21) are without merit and were obtained FRAUDULENTLY and WITHOUT BASIS of cause.

WHEREFORE, it is respectfully prayed that: (a) Prayer for judgment in favor of defendant with respect to plaintiffs complaint; (b) Prayer for judgment in favor of defendant with respect to counterclaim; (c) For such other relief consistent with law and equity and for costs (Venue, date, signature) Verification