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Sample ANSWER For Annulment of Deed of Sale
Sample ANSWER For Annulment of Deed of Sale
CHIWAWA PLAZA,
Plaintiff,
CIVIL CASE NO. 12345
-versus-
For: Annulment of Deed of Sale,
RIDEN BOY, Transfer Certificate of Title,
Defendant. Reconveyance and Damages
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ANSWER
(With COUNTERCLAIM)
Admissions / Denials
4. That there has been no agreement entered into by and between the
plaintiff and the defendant concerning the non-payment of loan for 5
years by reason that what has been executed is a deed of absolute sale
and such contract shall govern the parties thereto including his heirs and
assigns.
5. Plaintiff, just to justify and boost his claim cannot hide under the cloak
of illiteracy to escape from any liability and obligations arising out of
the contract of sale in order to defraud or work to the disadvantage of
the other party which in the case at bar is the defendant, because the
presumption of regularity in the execution of contract will govern
between the plaintiff and the defendant. Besides, the documents
executed by and between the defendant and the plaintiff is a duly
notarized document which constitute a notice to the whole world and as
such, it is highly improbable for the plaintiff to claim illiteracy when in
truth and in fact he can avail of a services of a lawyer in order to protect
his interest.
Counterclaim
Prayer
WHEREFORE, premises considered defendant, most respectfully
prayed of this Honorable Court that judgement be rendered:
a) Dismissing the complaint for utter lack of merit and cause of action.
b) Ordering the plaintiff to pay the defendant moral damages, attorney’s
fees and cost of litigation as prayed for in the preceding paragraph, and
c) And such other relief as may be deemed just and equitable under the
circumstance.
Copy furnished: