REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

National Capital Judicial Region
Branch 1
Taguig

JUAN DELA CRUZ

Plaintiff,

Civil Case No. 0001

For: Sum of Money

-versus-

PEDRO SANTOS
Defendant.
x----------------------------------------x

ANSWER

COMES NOW, the defendant by the undersigned counsel

and to this Honorable Court, respectfully alleges that:

1. Defendant admits that portion of par. 1 of the complaint

regarding the names, residences, and status of the parties, but
denies the rest thereof, for lack of knowledge sufficient to form a
belief as to the truth thereof;

2. Defendant denies under oath the execution and

authenticity of the promissory note, Annex “A” of the complaint, the
truth being that the same is a forgery and that he did not execute nor
sign the same;

3. By way of special and affirmative defenses, defendant

avers:
a. That the obligation has been paid; and
b. That the cause of action has prescribed.

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 4. By way if counterclaim, defendant alleges:
That by virtue of this unwarranted and malicious act
initiated by the plaintiff, defendant was forced to engage counsel in
the sum of TEN THOUSAND PESOS (Php 10,000.00).

WHEREFORE, it is respectfully prayed that the complaint

be dismissed and defendant be awarded the amount of ONE
HUNDRED THOUSAND PESOS (Php 100,000.00).

Other equitable reliefs are likewise prayed for.

City of Taguig, Philippines, March 3, 2015.

ATTY. CAROLINE EUSTAQUIO

Counsel for Plaintiff
145 Vista Verde Avenue Ext. 2, Cainta, Rizal
IBP No. 061320; 01/10/10 – Rizal
PTR No. 1234567; 01/10/10 – Rizal
Roll No. 12345; 5/05/05
MCLE No. I – 001234; 9/09/09
MCLE No. II – 005678; 9/09/09

VERIFICATION

I, Juan Dela Cruz, of legal age and a resident of 30 Capt.

Ciano St., Ibayo, Tipas, Taguig City, under oath declare that:

1. I am the plaintiff in above-entitled case;

2. I have caused the preparation of this complaint;

3. I have read it and its contents are true and correct of

my personal knowledge and/or based on authentic records.

(Sgd.) Juan Dela Cruz

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 JURAT

SUBSCRIBED AND SWORN to before me, in the City of Taguig, this

5th day of June, 2016, the affiant exhibiting his Driver's License No.
H01-11-000367 issued by the Land Transportation Office at the City
of Pasig on January 10, 2014 valid until January 12, 2017.

ATTY. JUANICO FRANCISCO

Notary Public for Taguig
Unit 45, X Building, Bonifacio Global City, Taguig City
Appointment No. 123,
Until December 31, 2016
IBP No. 123456; 01/10/10 – Taguig
PTR No. 1234567; 01/10/10 – Taguig
Roll No. 12345; 5/05/05
MCLE No. I – 001234; 9/09/09
MCLE No. II – 005678; 9/09/09
Serial No. of Commission M-123

Doc. No. 22;

Page No. 33;
Book No. V;
Series of 2016.

Copy furnished:
Juan Dela Cruz
30 Capt. Ciano St., Ibayo, Tipas, Taguig City

PROOF OF SERVICE