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Republic of the Philippines

Third Judicial Region

Regional Trial Court

Branch71

Iba, Zambales

TERESITA P. MCKENZIE, CIVIL CASE NO.: RTC-4459-2018-J


Plaintiff,

- versus - For: DAMAGES

REDEN A. ABLIAN, LYDIN ACEBEDO,


GUILLERMO ACEBEDO, ESTHER
ACEBEDO AND ZAMODCA TSMPCI,

Defendants.

ANSWER

Defendants, by counsel, unto this Honorable Court, most respectfully files her
Answer in response to the Complaint of the Plaintiff and interposes as well their
Counterclaim against the latter, to wit:

ADMISSIONS AND DENIALS

1. Paragraph 1 of the Complaint is specifically admitted;


2. Paragraph 2 of the Complaint is specifically admitted;
3. Paragraph 3 of the Complaint is specifically admitted;

4. Paragraph 4 of the Complaint is specifically admitted, except for the correct first name of
Defendant named REDEN A. ABLIAN to REDEL A. ABLIAN;

5. Paragraph 5 of the Complaint is specifically admitted as to the claim: That defendant


LYDIN ACEBEDO is the registered owner and operator of BLUE DAEWOO BUS with
conduction number 036401 and with body number OZ 14. Attached hereto is the machine
copy of the Official Receipt and Certificate of Registration of said vehicle marked and
attached as ANNEXES “1 and 2”;
6. Paragraph 6 of the Complaint is specifically denied as to the claim: That defendants
GUILLERMO ACEBEDO, ESTHER ACEBEDO are the registered owners and operators
of BLUE DAEWOO BUS with conduction number 036401 and with body number OZ 14;

7. Paragraph 6 of the Complaint is specifically denied as to the claim: That defendants


GUILLERMO ACEBEDO, ESTHER ACEBEDO are the registered owners and operators
of BLUE DAEWOO BUS with conduction number 036401 and with body number OZ 14;
8.
9.

10. Paragraph 8 of the Complaint is specifically denied due to: lack of personal knowledge
to either admit or deny the same;

11. Paragraph 9 of the Complaint is specifically denied due to: lack of personal knowledge
to either admit or deny the same;

12. Paragraph 10 of the Complaint is specifically denied as to the claim: that plaintiff’s driver
slowed down and that a motorcycle suddenly crossed the said highway, truth of the
matter being:

13. Paragraph 11 of the Complaint is specifically denied as to the claim: that defendant bus
recklessly bumped the rear portion of the plaintiff’s vehicle, truth of the matter being:

14. Paragraph 11 of the Complaint is specifically denied as to the claim: that defendant bus
recklessly bumped the rear portion of the plaintiff’s vehicle. The truth of the matter are
those as stated herein-below:

15. Paragraph 12 of the Complaint is specifically denied as to the claim: that. The truth of the
matter are those as stated herein-below:

16. Paragraph 13 of the Complaint is specifically denied as to the claim: that. The truth of the
matter are those as stated herein-below:

17. Paragraph 14 of the Complaint is specifically denied due to: lack of personal knowledge
to either admit or deny the same;

18. Paragraph 15 of the Complaint is specifically denied due to: lack of personal knowledge
to either admit or deny the same;

19. Paragraph 16 of the Complaint is specifically denied. The truth of the matter are those as
stated herein-below:

20. Paragraph 7 to 20 of the Complaint is specifically denied due to: lack of personal
knowledge to either admit or deny the same;

21. Paragraph 21 to 23 of the Complaint is specifically denied. The truth of the matter are
those as stated herein-below:
22. Paragraph 24 to 25 of the Complaint is specifically denied due to: lack of personal
knowledge to either admit or deny the same;

By way of counterclaim, defendants allege:

19. THAT by virtue of this unwarranted and malicious act initiated by the plaintiff,
Defendant was forced to engage the services of counsel in the sum of Twenty
Thousand Pesos (Php 20, 000.00) Philippine Currency, plus Php 2, 000.00 per
appearance in court; and the sum of Php 3, 000.00 for every subsequent pleading;

20. That by virtue of this unwarranted and malicious act and clearly groundless suit
initiated by the Plaintiff, Defendant was extremely embarrassed and humiliated,
causing her to suffer sleepless nights, mental anguish, physical anxiety, and
wounded feelings, for which the latter should be compensated in the amount of Php
100, 000.00 by way of moral damages; and

21. That to avoid repetition of the same and to set an example to the public, Defendant
should be compensated in the amount of Php 50, 000.00 by way of exemplary
damages.

PRAYERS

WHEREFORE, Defendants respectfully pray that the complaint be dismissed with


costs against the Plaintiff and that the Counterclaim of the Defendants be granted.

Other relief and remedies as may be deemed just and equitable under the premises
are likewise prayed for.

Mangatarem, Pangasinan for Iba, Zambales, Philippines. 14 February 2019.

DELA VEGA LAW OFFICE

(Counsel for Defendants REDEL A. ABLIAN, LYDIN ACEBEDO, GUILLERMO


ACEBEDO and ESTHER ACEBEDO)

Address: Room 3, Ground Floor, Twin Haven’s Inn, Gomez Street, Zamora (Poblacion),
Mangatarem, Pangasinan, Philippines

Of. Cellphone: 09982585428; and

E-mail:michaeldelavega_79@yahoo.com

____________________________________
ATTY. MICHAEL GOTOS DELA VEGA
Roll of Attorney No. 54447

I.B.P. O.R. NO. 0724; 01/04/2019; PANG. CHAP.


P.T.R. O.R. No. 4749248; 01/10/2019;Mangatarem, Pangasinan.
T.I.N. 253-955-126-000; 08-23-2007; and

M.C.L.E Compliance Certificate Number: V-0016700; 3/28/2016.

Conforme:

_______________________ _______________________
REDEN A. ABLIAN LYDIN ACEBEDO
(Defendant) (Defendant)

_______________________ _______________________
GUILLERMO ACEBEDO ESTHER ACEBEDO
(Defendant) (Defendant)

_______________________
ZAMODCA TSMPCI
(Defendant)

Date: 14 February 2019

To: THE BRANCH CLERK OF COURT

RTC - Branch 71

Iba, Zambales, Philippines


Greetings:

Kindly bring the foregoing Motion to the attention of the Honorable Court immediately
upon receipt thereof and set the same for hearing on __ day of ________ 2019, 8:30 o’clock
in the morning.

Thank you!

_____________________________

ATTY. MICHAEL GOTOS DELA VEGA

(Counsel for Defendants)

Copy furnished: Proof of Service


Reg. Rec.: _____________________
ATTY.DEO AMOR ALMAZAN DAVID Date:____________________
(Counsel for Plaintiffs) Place: ________________
192 Quezon St., Purok 4, San
Roque,Castillejos, Zambales

EXPLANATION

Service and Filing of the foregoing Entry of Appearance and Motion for Extension were
made thru registered mail with return card due to distance and lack of messengerial
personnel such that the same cannot be personally made.

_____________________________

ATTY. MICHAEL GOTOS DELA VEGA

(Counsel for Defendants)