Professional Documents
Culture Documents
Andrew Epal,
Plaintiff,
CIVIL CASE No. 16-74487
- versus SUMS OF
MONEY AND DAMAGES
For: COLLECTION OF
Gloc Nine,
Defendant.
X--------------X
MEMORANDUM
COMES NOW, Defendant, through the undersigned counsel
and to this Honorable Court, most respectfully states:
1. PRELIMINARY STATEMENT
1.1
1.2
1.3
That the defendant filed his answer on January 18, 2012, ten
days (10) after he received the said complaint and that his
answer is timely filed within this honorable court and within the
fifteen (15) day period required by the law;
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1.3
2. THE PARTIES
2.1
2.2
JBLFMU
duly
licensed
by
the
Professional
Regulation
Commission .
2.3
3.2
3.3
3.4
3
sale of his real property which he anticipated was to be the
3.5
4.2
4
giving it, or of non-payment or of
circumstances under which it was given.
the
In the instant case, the plaintiffs contention that he was not paid
by herein defendantis of no moment considering the fact that it
was based solely on the testimony of the said plaintiff and not on
any other independent evidence. Hence, having failed to adduce
sufficient rebuttal evidence, plaintiff is bound by the contents of
the receipt it issued to herein defendant Gloc Nine . The subject
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receipt remains to be the primary or best evidence or that
which affords the greatest certainty of the fact in question.
5. PRAYER
WHEREFORE, premises considered, it is most respectfully
prayed for this Honorable Court to render judgment in favor of the
Defendant and against the Plaintiff;
That the Plaintiff be ordered to pay the damages plus attorneys
fees and costs of litigation;
Other reliefs just and equitable under the premises are likewise
prayed for.
VERIFICATION
I, Gloc Ninel, Filipino, of legal age, a gun shop owner and a
resident of Brgy. San Agustin Iloilo City.
1. That I am the defendant in the above-entitled case;
2. That I caused the preparation of this Memorandum;
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3.
Gloc Nine
Defendant
SUBSCRIBED AND SWORN to before me this 9 of December 9,
2014 at Iloilo City with affiant exhibiting to me her Community Tax
Certificate No. 12345678 issued on December 1, 2014 at Iloilo City.
Doc. No. 12;
Page No. 3;
Book No. XII;
Series of 2014.
Copy furnished:
ATTY. Jose Vencer
ANGARA and ASSOCIATES
The Hotel Grande
Manila 2000 Philippines
Received by: __________________
Date: __________________________
Registry Receipt No. ____________
Date: __________________________
EXPLANATION
Due to the distance, copy of this Memorandum is served upon
the Office of the Solicitor General though registered mail under the
Registry Receipt hereto attached.
(SGD)
Jethro Villaruel