Republic of the Philippines

12th Judicial Region

MUNICIPAL TRIAL COURT
Branch 4
Iligan City

MAXIMO S. PRIME Civil Case No. 12345

Plaintiff, For: Ejectment
-versus-

SPOUSES ANTONIO Y. LAMANGAN

and GENOVIA G. LAMANGAN
Defendants,

X-------------------------/

ANSWER

Defendants, through the undersigned counsel, most respectfully file their

Answer in response to the Complaint of the Plaintiffs and interpose against the
latter, to wit:

ADMISSIONS AND DENIALS

1. Paragraphs 1,2,3,6, and 8 of the Complaint are admitted in so far as their

personal circumstances and personal knowledge are concerned;

2. Paragraph 4 of the Complaint is strongly denied for the fact that said
occupation by the Defendant is not by mere tolerance but by a Contract of
Lease hereto attached as Annex “A”.

3. Paragraph 5 of the Complaint is denied due to the fact that the Plaintiff has
knowledge that such “KASABUTAN” was not signed by the Defendants.
That such “KASABUTAN” was then made to another “Contract of Lease”
(Annex “B”) stating thereto that Defendants be notified five (5) months
before their evection.

4. Paragraph 7 is also denied since Plaintiff only made a single request made
orally, three (3) weeks prior to their eviction.

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 5. Paragraph 9 is vehemently denied due to the fact that that Defendant did not
maliciously and fraudulently acted with regards to vacating the said property
co-owned by the Plaintiff.

WHEREFORE, premises considered, it is respectfully prayed that the parties

be given ample time to reach an amicable settlement before the Mediation Center,
and that in case of a failure thereof, and after trial, the Complaint be dismissed for
lack of merit and Defendants Compulsory Counterclaim be granted, i.e., Attorney;s
fees plus moral damages of P80,000.00, plus cost of suit.

The Defendants respectfully pray for such and other reliefs as may be deemed
just and equitable in the premises.

Iligan City, 28 September 2018.

DELIMA LAW FIRM

131 Panay Reklamo Avenue, Aguinaldo Building
1103 Iligan City

RACQUEL M. DELIMA
PTR No. 8438426; 1/04/2007; Iligan City
IBP No. 568943; 1/04/2007; Iligan City Chapter
Roll of Attorneys No. 34328

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REPUBLIC OF THE PHILIPPINES )
CITY OF ILIGAN ) S.S.

VERIFICATION and CERTIFICATION

We, ANTONIO Y. LAMANGAN and GENOVIA G. LAMANGAN, both

Filipinos, of legal age, a residents of Barangay Saray, Iligan City, after having been
duly sworn to in accordance with law, do hereby depose and state;

1. That we are the Defendants in the above-entitled case;

2. That we have caused the preparation of said Answer thru my counsel;

3. That we hereby certify that we have read and understood all the denials
and admittance contained therein;

4. That the contents therein are true and correct to the best of our personal
knowledge and based on documents in our possession;

5. That we further certify that there is no other action pending between the
same parties for the same cause of action and subject matter before the Supreme
Court, the Court of Appeals, or any other court or tribunal, and we hereby warrant
that if one is filed, or is known to exists, we will forthwith inform or notify this
Honourable Court within five (5) days from notice thereof.

IN WITNESS WHEREOF, I have hereunto set my hand on this ___ day of

September, 2018 at Iligan City, Philippines.

ANTONIO Y. LAMANGAN
GENOVIA G. LAMANGAN
Affiant(s)

SUBSCRIBE AND SWORN to before me on ____ day of _________, 2018,

affiant having exhibited to me his Community tax Certificate No. __________
Issued on ____________, Issued at ______________.

Doc No. ____

Page No. ____ ATTY. CARLO Z. SUAREZ
PTR No. 5431011 – 1/3/18 - Iligan City
Book No. ____ IBP Lifetime No. 010393/Iligan City Chapter
Series of 2018. MCLE Compliance No. V-0006521
Roll of Attorneys No. 88010

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