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Republic of the Philippines

Regional Trial Court
Tenth Judicial Region
Iligan City






For: Sum of Money


COMES NOW, defendant, by counsel, under oath do hereby depose
and state:


1. He admits the allegations contained in paragraph 2;

2. He is without knowledge or information sufficient to form a belief as
to the truth in the allegations set forth in paragraph 4;

3. He specifically denies as to the allegations set forth in paragraph 3, 5,
and 6. That in truth and in fact, defendant only owes complainant a
certain sum of money amounting to THREE HUNDRED PESOS (Php
300,000.00) and such debt was already paid by defendant sometime
June 2, 2013 as evidenced by the receipt (Herein attached as ANNEX
1); that although defendant have received a copy of the final
demand letter (Herein attached as ANNEX 2) he just ignored it due
to the fact that the debt has long been paid; that defendant have not
appeared in the said mediation and conciliation proceeding for all he
thought that it would be useless for him to go as because the debt
has already been paid;

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4. That complainant has no cause of action in the foregoing complaint
for sum of money;

4.1 That for complainant to have a cause of action against the
defendant, according to the law, one must establish that: (1) there is
an existing debt; (2) such debt is due and demandable; (3) there has
been a demand for the collection of debt; and (4) that the debt has
not been paid;

4.2 In the foregoing instance, such allegations are futile for the
defendants debt was lng ago paid by him, even prior to the arrival of
the said due date stated in the acknowledgement receipt (Herein
attached as ANNEX 3);


WHEREFORE, defendant respectfully prays from this Honorable Court
to render judgment in his favor and order complainant to pay him
FIFTY THOUSAND PESOS (Php 50,000.00) as moral damages and
NINETY THOUSAND PESOS (Php 90,000.00) as attorneys fee.

Defendant now also prays for other and further relief as may be
deemed just and equitable in the premises.

Atty. Juan dela Cruz
Notary Public
Pala-o, Iligan City
Roll No. xx1
IBP No. xxx5
PTR No. xx3
MCLE NO. xx7

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I, DEF, of legal age, under oath, hereby depose and say:

I am the defendant in the foregoing complaint for sum of money;

I have caused the preparation of the said complaint and have read and
understood the same;

I hereby affirm that all the factual allegations in the said complaint are true
and correct as to my personal knowledge and belief; as well as true and
correct on the basis of the authentic documents and records in my

I certify that I have not heretofore commenced any action or have filed any
claim involving the same issue in any court, tribunal, or quasi-judicial

If I should have hereafter know of other similar actions or claim which is
pending to any other court, tribunal, or quasi-judicial agency, I shall report
said fact or knowledge within five (5) days from my knowledge to the
Honorable Court.


SUBSCRIBED and SWORN to me this 9
day of July, 2014. Affiant appeared
personally and exhibiting to me his Community Tax Certificate bearing no.
XYZ0001 issued on July 01, 2014 at Iligan City.

Doc No.
Page No.
Book No.
Series of 2014.
Atty. Juan dela Cruz
Notary Public
Pala-o, Iligan City
Roll No. xx1
IBP No. xxx5
PTR No. xx3
MCLE NO. xx7
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Copy furnished:

Atty. John Doe
Counsel for Plaintiff
Pala-o, Iligan City