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ANSWER (Civil)
ANSWER (Civil)
XXXXX,
Plaintiff,
Civil Case No.
‐ versus For: Sum of Money
YYYYY,
Defendant.
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ANSWER
(With COUNTERCLAIM)
4. The complaint does not state a cause of action and is a sham pleading;
4.2 Due to a close and long relationship with Plaintiff, Defendant was deceived
into signing a receipt which he thought contained only a reasonable rate of
interest per Defendant’s oral agreement with Plaintiff;
4.3 Upon securing a copy of the receipt much later, Defendant discovered to his
utter surprise that the rate of interest indicated on the receipt is five (5%)
percent per month, or sixty (60%) percent per annum;
5. Defendant additionally submits that he is entitled to relief arising from the filing of
this malicious and baseless suit, as follows:
5.1 Moral Damages amounting to Fifty Thousand Pesos (P50,000.00) because his
name and reputation were besmirched by this malicious and baseless suit.
5.2 Despite full payment by Defendant of the principal obligation, Plaintiff has
instituted the instant malicious suit which compelled Defendant to engage the
services of counsel, in order to protect Defendant’s interests, for an agreed
professional fee of P200,000.00, plus an appearance fee of P5,000.00 per
hearing.
5.3 Defendants also incurred other litigation expenses in the sum of P 50,000.00.
For all of said fees and litigation expenses, Plaintiff should be adjudged liable
to Defendant.
Other just and equitable reliefs are prayed for. Quezon City for Muntinlupa City,
October 11, 2007.
Cagayan de Oro City, July 5, 2008.
ZZZZZ
Counsel for Defendant
Ternate Bldg, Carmen,
Cagayan de Oro CIty
Attorney’s Roll No. 35748
IBP No. 23875‐01/03/08 Mis Or. PTR No. 453321‐01/03/08 CDO
MCLE Compliance No. II‐0005676‐Nov. 17, 2007