REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

NATIONAL CAPITAL JUDICIAL REGION
MAKATI CITY, BRANCH 111

BI LAND HOLDINGS, INC.,

Plaintiff,

Civil Case No. 2020-001

- versus - For: Specific Performance with
Damages

DMSI, INC.,
Defendant.
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ANSWER

Defendant DMSI, INC. (“DMSI”), by counsel, respectfully states:

Denials

I. Specific Denials

1. For the reasons stated in the succeeding paragraphs, as well as

in the Affirmative Allegations and the Affirmative Defenses below,
Defendant DMSI, INC. (“DMSI”) specifically denies the allegations in the
following paragraphs of the complaint:

1. Paragraph 6 is denied insofar as the allegation that DMSI only sent

a letter informing BLHI of the decision of DMSI’s Board of Directors
not to pursue the transaction on September 16, 2020 as it was sent on
September 10, 20201
2. Paragraph 8 is denied insofar as the allegations that plaintiff BLHI
has not received any response from DMSI;2

1
A copy of the letter dated September 10, 2020 is attached as Annex B; 0 (“Mr. X
Affidavit”, attached as Annex A), at p. 1.
2
A copy of an affidavit of service executed by Mr. A dated September 19, 2020 is
attached as Annex C;
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II. For Lack of Knowledge or Information

2. Defendant DMSI, INC. (“DMSI”) specifically denies the

allegations in the following paragraphs of the complaint for lack of
knowledge or information sufficient to form a belief as to the truth of their
allegations:
3. Paragraph 4 is denied for lack of information or knowledge
sufficient to form a reasonable belief that Mr. Juan Dela Cruz was
properly authorized to sign the acceptance letter for or in behalf of
BLHI;3
4. Paragraph 9 is denied for lack of information or knowledge
sufficient to form a reasonable belief thereof;

III. Conclusory and/or Speculative

3. The following paragraphs of the complaint are denied for being

conclusory and/or speculative:

[identify the paragraphs and state the reasons for the denial]

Affirmative Allegations

3. In support of her Specific Denials, Affirmative Defenses, and

Compulsory Counterclaim, [party] respectfully states:

[state relevant and material facts, with reference to supporting

documentary and testimonial evidence]

Affirmative Defenses

4. [party] repleads the allegations in the preceding paragraphs.

[discuss and apply relevant law/case law to facts]

Counterclaim

3
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5. [party] respectfully reiterates, repleads, and incorporates by

reference here all the allegations in the preceding paragraphs.

[discuss and apply relevant law/case law to facts]

PRAYER

WHEREFORE, [party] respectfully prays that this Honorable Court

[state reliefs sought].

[party] prays for other just and equitable relief.

[place/date].

[counsel’s details]

COPY FURNISHED:

[opposing party’s/counsel’s details]