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REPUBLIC OF THE PHILIPPINES

7th JUDICIAL REGION


MUNICIPAL TRIAL COURT IN CITIES
City of Cebu, Branch 3

JUAN DELA A. CRUZ,


Plaintiff,

- versus - CIVIL CASE NO. M-011035


For: Collection of a sum of money and
Damages

PEDRO A. SANTOS,
Defendant.
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REPLY WITH MOTION TO SET PRE-TRIAL

PLAINTIFF, by undersigned counsel, unto the Honorable Court, most


respectfully manifest that on February 3, 2017, he received a copy of the
ANSWER WITH COMPULSORY COUNTERCLAIMS of Defendant in
the above-entitled case and, by way of a REPLY to new matters alleged
therein, hereby state THAT:

1. The allegation in Paragraph 8 of the Answer with Compulsory


Counterclaim is specifically denied, the truth being that alleged in
the Complain;

2. Paragraphs 9, 10, 11, and 12 are specifically denied for lack of


knowledge sufficient to form a belief as to the truth or falsity
thereof;

3. The allegation in Paragraph 13 is admitted insofar as the Plaintiffs


refusal to acknowledge the receipt issued by the Plaintiffs wife,
the truth being that the Plaintiff did not authorize any other person,
including his wife, to receive payment from the Defendant;

4. Paragraphs 14, 15, and 16 are specifically denied, the truth being
that the present action is well-founded in fact and in law, filed in
good faith to protect and vindicate the rights of the Plaintiff
violated by the Defendant; therefore, there is no basis whatsoever

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for the Defendant to recover any damages, attorneys fees nor
expenses of litigation from the Plaintiff;

II

The issues are joined. The case is ripe for pre-trial.

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of


this Honorable Court that the counterclaim of the Defendant be dismissed
and that the case be set for pre-trial

Cebu City, February 6, 2017.

PABUAYA & SANTOS LAW OFFICE


Counsel for the Plaintiff
Room 204, CRM Building,
Escario cor. Molave Sts., Lahug,
Cebu City 6000
Telephone Number: (032) 253-1890 to 91
Fax Number: (032) 253-1892
E-mail Address: inquiry@pslawoffice.com

By:

ATTY. CRISTIE PEARL O. PABUAYA


Roll No. 374435
IBP No. 827847, 01/04/17, Cebu City
PTR No. 576784, 01/04/17, Cebu City
MCLE Compliance No. V-0008811
Telephone No. (032) 253-1890 local 101
E-mail Address: cpopabuaya@pslawoffice.com

ATTY. MARIA EMMA C. SANTOS


Roll No. 383325
IBP No. 8448436, 01/05/17, Cebu City
PTR No. 599013, 01/05/17, Cebu City
MCLE Compliance No. V-0008815
Telephone No. (032) 253-1890 local 102
E-mail Address: emecsantos@pslawoffice.com

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Copy furnished, in accordance with
Section 11, Rule 13 of the Revised
Rules of Court, by registered mail,
due to shortage of messengerial
services, to:

CORCUERA & OTADOY LAW OFFICE


Counsel for the Plaintiff
Unit 164, SCR Building,
General Maxilom Avenue,
Cebu City 6000

ATTY. ALVIN Q. VASQUEZ


Clerk of Court
Municipal Trial Court in Cities,
Cebu City, Branch 9,
3/F Qimonda IT Center,
Sergio Osmea Boulevard,
Cebu City