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(Caption and Title)

DEFENDANT, through counsel, answering plaintiff's complaint,


alleges:
ANSWER TO FIRST CAUSE OF ACTION
1. Defendant ADMITS the allegations in paragraph 1, 2 and 3 of the
First Cause of Action.
AFFIRMATIVE TO SECOND CAUSE OF ACTION
1. Defendants ADMITS the allegation in paragraph 1 of the Second
Cause of Action.
2. Defendant ADMITS the allegation in paragraph 2, to the effect
that he used defendant's cargo truck for a trip to Gattaran, Cagayan;
but DENIES that he did so on a contract of hire for Php 13,000.00,
the truth being that defendant took said truck as aforementioned on a
joint business trip between plaintiff and defendant, the understanding
being that plaintiff would give the use of the truck free, as part of his
contribution to the venture.
COUNTERCLAIM COMMON TO BOTH CAUSES OF ACTION
1. That defendant invested Php 55,000.00 in the aforementioned
business trip to Gattaran, Cagayan, and plaintiff invested Php
36,000.00, plus the use of his truck, with understanding that they
would divide the profits or losses equally between them.
2. That defendant bought Php 60,800.00, worth of coconuts in said
trip, transported the same to Manila, and delivered all the coconuts to
plaintiff who would sell the same.
3. That all the coconuts have already been sold, at a total price of at
least Php 234,600.00.
4. That plaintiff has not rendered any accounting of the proceeds of
said sales, nor has he given to defendant any portion of latter's
capital or profits, notwithstanding demands therefor.
WHEREFORE, defendant prays that plaintiff's complaint be
dismissed, with costs against plaintiff; and on defendant's
counterclaim, that plaintiff be ordered to render to defendant a full
and complete accounting of the result of the business venture, and of
all the money derived therefrom, and, forthwith, to pay to defendant
the capital invested by the latter, i.e., Php _________ plus ____% of
the total net profit.