FORM NO. 22.

ANSWER (FOR UNLAWFUL DETAINER)

REPUBLIC OF THE PHILIPPINES

METROPOLITAN TRIAL COURT
City of Manila
Branch 1

PAUL CASUGA,
Plaintiff,

-versus-
CIVIL CASE No. 75643
FOR: Unlawful Detainer

CHRISTY SALONGA,
Defendant.

ANSWER

DEFENDANT, CHRIST SALONGA, by herself, and to this Honorable Court, most respectfully alleges that:

1. Defendant admits the allegation in paragraph 1, 2 and 3 of the complaint only insofar as the fact
that the name of Paul Casuga is indicated in the Transfer Certificate of Title No. 79123, without
prejudice to the Memorandum of Encumbrances indicated therein;

2. Paragraph 4 is admitted as to the consideration of the contract and date of payment.

3. Paragraph 5, 6, 7 and 8 is denied because the defendant has no knowledge or information

sufficient to form a belief as to the truthfulness of the averments in paragraph 5 to 8 of the
complaint; that the defendant was able to comply with its obligation to pay the monthly rentals
agreed upon within the stipulated day secured with the receipts of rentals.

SPECIAL AND/OR AFFIRMATIVE DEFENSES

Defendant hereby re-pleads all the foregoing allegations and, by way of special and/or
affirmative defences states that:
 4. The defendant have been leasing an apartment located in Mayhaligue Street Manila with a
mothly rental of P6,000.00;

5. That the subject property is covered by Transfer Certificate of Title No. 79123 registered under
the name Paul Casuga;

6. That defendant was able to fulfill its monthly obligation which is the payment of monthly rentals
as stipulated in the contract evidenced by the receipt of rentals.

7. That the Plaintiff failed to attached documents to prove that the Defendant in fact did not pay
the monthly rentals.

COUNTERCLAIM

Defendant Christy Salonga alleges;

1. That by virtue of the unwarranted and malicious act initiated by the Plaintiff, Defendants were
forced to engage counsel in the sum of Ten Thousand Pesos (P10,000.00)

WHEREFORE, it is respectfully prayed that the complaint be dismissed and defendant be awarded in the
amount of Twenty Thousand Pesos (P20, 000.00)

Other just and equitable reliefs are likewise prayed for.

Atty. James Bond

Quezon Avenue, Manila
IBP No. 927307, Manila 1-2912
PTR No. 3202399, Quezon Avenue Manila, 1-21-13
MCLE Compliance No. 1110016263, 05-31-10

VERIFICATION/CERTIFICATION
I, Christy Salonga, of legal age, Filipino Citizen and residing at 753 Maliwanag
Street, Manila, Philippines after first having duly sworn to in accordance with law
depose and say;
1. I am the defendant in the above-entitled case;
2. I have caused the preparation of the foregoing complaint;

3. The contents therein are true and correct to the best of my personal
knowledge and based on authentic documents;
 4. I hereby certify that I have not commenced any action or proceeding
involving the same issue in any tribunal or agency, to the best of our own
knowledge, no such action or proceeding is pending in any other tribunal or
agency and should I learn that a similar action or proceeding has been filed
or is pending in Court, I will undertake to report such fact within five (5)
days therefrom to the court wherein this Petition and this certification have
been filed.

IN WITNESS WHEREOF, I have hereunto affixed my signature this 4 th day of

December 2012.

Christy Salonga
Affiant
SUBSCRIBE AND SWORN to before me this 4 th day of December 2012 in
Manila, Philippines.
Joselle Rivera
Roll of Attorney No. 98765
IBP No. 12345/2-5-12/Manila
PTR No. 87654/12-22-11/Manila
MCLE Compliance No. 1110016263,05-31-10