REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

6TH JUDICIAL REGION
BRANCH 6
ILOILO CITY

Re: In the Matter of the

Guardianship of the Minor
Daniel Padilla
Sp. Proc. No. 12345
Bea P. Padilla,
Respondent,
x-----------------------------------x

ANSWER

COMES NOW, respondent, in the above-entitled case, through the

undersigned counsel, and unto this Honorable Court, most respectfully
states, that:

1. He is the biological father of Daniel Padilla, that was alleged to be

dead as stated in the petition by the petitioners;

2. Respondent admits the allegations in paragraph 1 of the petition in so

far as the personal circumstance of the respondent is concerned.

3. Respondent admits the allegations in paragraph 2 of the petition;

4. Respondent specifically denies the allegations that he abandoned his

family as contained in paragraph 4 of the petition for lack of
knowledge sufficient to form a belief regarding the truth or falsity
thereof;

5. That the respondent admits that he is married to Karla Estrada, and

they begot a child named Daniel on April 11, 2001;

6. That the respondent contends that he is not in favor of the

guardianship procedure of his daughter.

WHEREFORE, premises considered, it is most respectfully prayed to

this Honorable Court to:

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 1. Issue an Order dismissing the petition for guardianship between the
petitioners and the minor Therese Lee;

2. Order the petitioners to pay the respondent the amount of P20,000.00

as attorneys fees and P5,000.00 as appearance fees for every
scheduled hearing.

Other reliefs and measures just and equitable under the premises and
likewise prayed for.

Iloilo City, Philippines, March 20, 2017.

ATTY. NONITO Q. PASUELO, JR.

Counsel for the Respondent
IBP No. 041696 12/1/2016
PTR No. 1679823 12/1/2016
Roll of Attorneys No. 66199
MCLE Comp No. IV-0006192 6/14/16

EXPLANATION

(Pursuant to Sec. 11 Rule 13 of the 1987 Rules of Civil Procedure)

The undersigned counsel is constrained to furnish the Counsel for the

Petitioner the foregoing Answer by registered mail due to distance that
renders personal filing impracticable and costly.

ATTY. NONITO Q. PASUELO, JR.

COPY FURNISHED:

ATTY. LUCY LIU

Counsel for Plaintiff
Until December 31, 2017
Roll of Attorneys No.: 757527
PTR No.: 2024144/06-06-16 Iloilo, City
IBP No.: 894045- Lifetime; Iloilo City
MCLE Compliance No.: III-007415
3rd Floor, Golden Commercial Center, Iznart St., Iloilo City

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REPUBLIC OF THE PHILIPPINES)
CITY OF ILOILO)S.S
X--------------------------------------------------X

VERIFICATION/CERTIFICATION OF NON-FORUM SHOPPING

I, Robin Padilla, of legal age, married, and a resident of San Vicente

St. Jaro, Iloilo City, after having been duly sworn to in accordance with law,
do hereby depose and say:

1. That I am the respondent in the above-entitled case;

2. That I have caused the preparation of the foregoing Answer;

3. That the allegations contained therein are true and correct of my own
knowledge and belief and based on authentic records;

4. That we have not filed any similar petition in any court or agency of
the government of the Republic of the Philippines and if there is any
such petition, we undertake to report the same to this Honorable Court
within five (5) days upon learning that such petition has been filed.

IN WITNESS HEREOF, we have hereunto set our hands this 10th

day of March 2017, in Iloilo City.

Robin Padilla
Affiant

SUBSCRIBED AND SWORN TO before me this 10th day of March

2017, in Iloilo City, Philippines, affiant exhibiting to me their Philippine
Passport No. 12345 and 67891, issued in Iloilo City on January 5, 2016 and
valid until January 5, 2019.

ATTY. NONITO Q. PASUELO, JR.

Notary Public
IBP No. 041696 12/1/2016
PTR No. 1679823 12/1/2016
Roll of Attorneys No. 66199
MCLE Comp No. IV-0006192 6/14/16
XYZ Building, Jaro, Iloilo City
Doc. No.: _____;
Page No.: _____;
Book No.: _____;
Series of 2017.