Professional Documents
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ANSWER
DEFENDANTS, through counsel, answering plaintiffs complaint, alleges:
1. That except for the personal circumstances referring to defendants, the
rest of the averments in paragraph 1 of complaint is hereby DENIED for
lack of information or knowledge sufficient to form a belief as to its
truth;
2. That except for defendant ANA C. TELLO who has no participation
whatsoever in the execution of said Deed of Transfer of Rights and
Improvements Over a Parcel of Unregistered Land, the rest of
the
1. That,
at
the
time
the
Deed
of
Transfer
of
Rights
and
PRAYER
WHEREFORE, in view of the foregoing, defendants humbly
pray to this Honorable Court, after due hearing, to adjudge Plaintiff
to pay defendants the following:
1. Sentencing Plaintiff to pay defendants moral damages valued in
an amount of not less than P100,000.00;
2. Sentencing Plaintiff to pay defendants exemplary damages
valued in an amount of not less than P50,000.00;
3. Sentencing Plaintiff to pay defendants nominal damages valued
in an amount of not less than P50,000.00;
4. Sentencing Plaintiff to pay defendants P30,000.00 as Attorneys
fees plus P1,500.00 appearance fee for every record court
appearance; and
5. Sentencing Plaintiff to pay the cost of suit;
Other reliefs just and equitable are likewise prayed for.
Baguio City for La Trinidad, Benguet, this 21 st day of September, 2011.
RHEINA B. LAPEA
Counsel for the Defendants
B-319, 3/F, Lopez Building
Session Road, Baguio City
Roll No. 60885
PTR No. 1641702, 01-02-11, B.C.
IBP No. 643425, 01-02-11, B.C.
3
VERIFICATION
MA.TERESA CANTORES, after having been duly sworn to in accordance
with law, hereby depose and state:
1. That she is one of the defendants in the above-entitled case;
2. That she caused the preparation of the foregoing pleading and to
the best of her knowledge all the foregoing allegations are true;
MA. TERESA CANTORES
Affiant
SUBSCRIBED AND SWORN to before me this 21 st day of September,
2011. Affiant having exhibited to me her Social Security System Identification
Card bearing No. 03094507, issued on November 12, 2009 issued at Baguio
City.
RHEINA B. LAPEA
Notary Public
N.A. No. 33-NC-05 (R)
Commission expires on December 31, 2011
R.O.A. No. 60885
PTR No. 1641702, 01-02-06, B.C
IBP No. 643425, 01-02-06, B.C.
B-319, 3/F, Lopez Bldg., Session Rd., Baguio City