ANSWER For, Quieting of Title,

Recovery of Possession,
Prayer for the Issuance of a
Writ of Preliminary Mandatory
Injunction and Damages
Gomez v. Putoksabuho
Page 2 of 8
x-----------------------------------------x

a. Defendants seriously doubt the identities of the

plaintiff;

(i) From age of reason, they have been living

with Ama Gomez, the live in partner of their
widowed mother, who never told them that he
was married nor that he has children;

(ii) They have never seen the Plaintiffs and only

came to know their existence when they were
summoned for barangay conciliation.

b. No cloud of title, titles to land having obtained

through fraud and misrepresentation;

(i) Ama Gomez never owned the lands as they

are owned by their maternal grandparents,
photocopies of such titles are herewith
attached as ANNEX “1” to “1a”;

(ii) Ama and their mother were never married.

c. Defendants’ possession was never interrupted until

the complaint in the barangay;

(i) The two parcels of land was in the possession

of the parents of their mother and were
handed down to their mother and father to till;

(ii) It was tilled by their mother with the helped of

Ama;

(iii) They continued to till the land when Ama

died;

COUNTERCLAIM

6. Due to the malicious filing of this instant suit under guise of a

legal or equitable title:

a. Defendants seeks to nullify OCTs T-202 and T-207 and

reconvey the ownership of the lands to them;
 ANSWER For, Quieting of Title,
Recovery of Possession,
Prayer for the Issuance of a
Writ of Preliminary Mandatory
Injunction and Damages
Gomez v. Putoksabuho
Page 2 of 8
x-----------------------------------------x