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Republic of the Philippines

Department of Justice
Office of the City Prosecutor
xxxxxxxxxxxxx

xxxxxxxxxxx
Complainant, Docket No.: xxxxxxxx

-versus-
For: ECONOMIC
ABUSE
Under R. A. 9262 or the
Anti-
xxxxxxxxxxxxx
Respondent. Children

X-------------------------------------------x.

COUNTER–AFFIDAVIT

I, xxxxxxxxxxxxxxx, of legal age, Filipino, married to


Complainant, xxxxxxxxxxx, residing at No.
xxxxxxxxxxxxxxxx, La Loma, Quezon City, a
xxxxxxxxxxxxxxx by profession, under oath in
accordance with law, hereby depose and say that:

1. I am the Respondent in the instant Complaint for


Economic Abuse under R. A. 9262 or the Anti-Violence
against Women and Children Act;

2. Paragraphs 3 and 4 of the Affidavit-Complaint are


hereby admitted and adopted;

3. Paragraph 5 of the Complaint-Affidavit is hereby


denied for lack of proof of such display of irrational
behavior and that until now, I have been a responsible
husband and father to my family;

4. When I was transferred to xxxxxxxxxxxxxxxxx, my


wife, Bianca, and I have agreed to rent an apartment in
Quezon City so that we would reside there for some days
in week while still maintaining our house in Makati as our
main place of residence. The purpose for the acquisition of
the apartment is for me to be readily available for the
hospital when I am ‘On Call’ and avoid the hassle of a long
trip from our house in Makati to the Hospital in Quezon
City;

5. xxxxxxxxxxxxxxxxxxxxxxxxx

6. xxxxxxxxxxxx rejected my proposal that we should


reside in Quezon City for the duration of my residency in
the Capitol Medical Center saying that she does not like
living in Quezon City and the children’s friends are in
Makati. We argued for days and then came to an
agreement that she and the children will stay in our house
in Makati permanently and I will stay in the apartment in
Quezon City during workdays and when I am on call, but
will go home to Makati during my days off and when my
work load is not to heavy;

7. xxxxxxxxxxxxxxxxx

8. xxxxxxxxxxxxxxxx

9. xxxxxxxxxxxxxxxx;

10. The allegations in Paragraphs 13 and 14 of the


Complaint-Affidavit are hereby denied for being false. The
alleged marriage between myself and one xxxxxxxxxxxxx
does not exist. The xxxxxxxxxxxxx attached to the

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xxxxxxxxxxxxx is for another xxxxxxxxxxx and an
xxxxxxxxxxx who are strangers to me and to our family;

11. For the past three weeks, my wife,


xxxxxxxxxxxxxxx, has refused to talk with me in person
despite my continuous effort to communicate with her.
She also does not to allow me to see my children, causing
me anxiety and to suffer emotional pain;

12. In spite of this Complaint for Economic Abuse that


xxxxxxxxxxxx has prejudicially filed, and despite the fact
that she has emotional and psychological issues that need
to be addressed by seeking professional help, like her
gambling addiction, I still and will continue to love her and
honor the commitment I made with her when we got
married;

13. I have caused the preparation of this Counter-Affidavit.

IN WITNESS WHEREOF, I have hereunto set my hand


this 10th day of April 2017 at Quezon City, Philippines.

xxxxxxxxxxxxxx
x

Respondent/Affiant

SUBSCRIBED AND SWORN to before me this xxth day of


xxxx xxxx in Makati City, Philippines.

xxxxxxxxxxxxxxx
Counsel for
Respondent
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