REPUBLIC OF THE PHILIPPINES

METROPOLITAN TRIAL COURT

City of Manila
Branch 1

JUNABEL ACORTE,
Plaintiff,
CIVIL CASE No. 30963
-versus- FOR: Unlawful Detainer

MICHAEL VIRTIGO,
Defendant.
x--------------------------------------------x

ANSWER

COMES NOW, the defendant, through the undersigned counsel and unto this Honorable Court,
most respectfully avers:
1. That he ADMITS the contents of paragraph 2 only insofar as his personal circumstances are
concerned;
2. That he ADMITS his obligation of paying the monthly installments cited in paragraph 4 of the complaint,
but DENY the rest of the allegations therein as said defendant’s obligation to plaintiff is faithfully
complied with through monthly payments to the plaintiff’s mother, JUNIPER ACORTE, as her
representative;
3. That defendant does not, at the moment, have all the records of payments he made to JUNIPER
ACORTE, so that he also does not have information sufficient to form a belief as the truth of the
allegations in paragraph 5 of the complaint and, therefore, DENY them;
4. That defendant is without knowledge or information sufficient to form a belief as to the veracity of the
averments in paragraph 6 of the complaint.

WHEREFORE, the defendant respectfully prays that the complaint be dismissed with costs
against the plaintiff.

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

City of Manila, September 28, 2012.

GACUTAN AND SALAZAR LAW OFFICE

Counsel for the Defendant
Suite 258 The Tower
Malate, Manila

By:
ARVIN GACUTAN
Roll No. 98765
IBP No, 12345/1-3-2012/Manila
PTR No. 34567/1-3-2012/Manila
Republic of the Philippines )
City of Manila ) S.S.

VERIFICATION

I, MICHAEL VIRTIGO, of legal age, Filipino citizen, single, with residence and postal address
at 456 Modesto Street, Manila, under oath, depose:

1. That I am the Defendant in the above-entitled case.

2. That I caused the preparation of, and have read, the foregoing Answer and confirm that
the factual allegations therein are true and correct of my own personal knowledge and/or
based on verifiable information or authentic records.

IN WITNESS WHEREOF, I have hereunto set my hand this 28th of September 2012, in the
City of Manila.

MICHAEL VIRTIGO

SUBSCRIBED AND SWORN to before me this _______ day of September, 2012, in the City
of Manila, affiant exhibiting to me his Driver’s License No. 45637 issued by the Land Transportation
Office on March 14, 2012 at the City of Manila.

ATTY. GERONIMO ALTO

Notary Public
My Commission Expires Dec. 30, 2012
Roll of Attorney No. 23165
IBP No. 23415/2-5-12/Manila
PTR No. 54354/12-22-11/Manila

Doc. No. ________

Page No. _______
Book No. _______
Series of 2012.
COPY FURNISHED:

ATTY. LOUISE REYES

Counsel for the Plaintiff
Unit 123, Victoria Tower I
Taft Avenue, Manila

EXPLANATION
A copy of the foregoing Verified Answer was served on counsel for the Petitioner via
registered mail instead of the preferred mode of personal service due to distance and lack of
messengers in the office of undersigned counsel.

ARVIN GACUTAN