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Answer 3
Answer 3
VANGIE G. UTANGAN
Plaintiff, Civil Case No. 2018-092414
For: Collection of Sum of
-versus- Money with Damages
ANSWER
4. Defendant vehemently denies under oath paragraph 8, the truth being that,
the Defendant did not acted fraudulently and has no intention to evade her
obligation with the Plaintiff.
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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 Defendant Compulsory Counterclaim be granted, i.e., Attorney
fees plus moral damages of P50, 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.
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.
3. That I hereby certify that I have read and understood all the denials and
admittance contained therein;
4. That the contents therein are true and correct to the best of my personal
knowledge and based on documents in my possession;
5. That I 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.
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