Republic of the Philippines

First Judicial Region

MUNICIPAL TRIAL COURT
Bauang, La Union

JUAN C. GOMEZ
and/or on behalf of
PEDRO C. GOMEZ
Plaintiffs,

-versus- Civil Case No.__________

For Quieting of Title,
Recovery of Possession,
Writ of Preliminary
Injunction
and Damages

X Putoksabuho
and Y Putoksabuho,
Defendants.
x- - - - - - - - - - - - - - - - - - - -/

ANSWER
WITH AFFIRMATIVE DEFENSES AND COUNTERCLAIM

DEFENDANTS, thru counsel unto this Honorable Court

respectfully state that:

1. Paragraph 1 of the Complaint is denied for lack of knowledge

sufficient to form a belief as to the truth thereof;

2. Paragraph 2 of the Complaint is admitted;

3. Paragraphs 3 and 4 of the Complaint and their subparagraphs

are specifically denied as the truth being that stated in the Affirmative
Defenses, except subparagraph 4.3 is admitted;

4. Paragraphs 5, 6, 7, 8, 9, 10, 11, 12, 13, and 14 of the Complaint

are denied for lack of knowledge sufficient to form a belief as to the
truth thereof.

AFFIRMATIVE DEFENSES
5. The Complaint filed by the Plaintiffs is nothing but a malicious
fabrications under guise of a legal or equitable title: