Republic of the Philippines

Regional Trial Court

Branch 20
Catarman, Northern Samar

AAA DELA CRUZ,

Plaintiff,
Civil Case No. 000001
-versus- For: Sum of Money
with damages
BBB DE ASIS,
Defendant.
x-------------------------x
ANSWER

DEFENDANT BBB DE ASIS, by undersigned counsel, unto this honorable

court most respectfully states that:

1. Paragraphs one (1) and two (2) of the content of the Complaint are admitted;

2. Paragraphs three (3) to five (5) of the Complaint are denied for lack of
knowledge or information sufficient to form a belief as to the veracity or falsity thereof,
the allegations therein being matters known only to and are within the control only of the
plaintiff;

3. Paragraph six (6) of the Complaint is denied insofar as it alleges that the
defendant owes the plaintiff a sum of money and fails to pay the same, the truth being
those alleged in the special and affirmative defenses part herein below;

SPECIAL AND AFFIRMATIVE DEFENSES

1. On December 2018, the defendant and the plaintiff did not see each other
because the former was having a vacation in Boracay Island as evidenced by
the photocopy of entry/ exit of vehicles monitoring sheet, attached herein,
marked as Annex “A”, and made an integral part hereto. Such monitoring sheet
is issued by the Gate Security Department of the Subdivision where the
defendant resides.
2. The plaintiff never gave the defendant the alleged amount; that the defendant
did not sign the alleged promissory note; and that Defendant’s signature is
forged.

3. On March 2019, the Defendant and the Plaintiff did not see each other because
the former visited her late grandmother in Legazpi, Albay as evidenced by the
photocopy of entry/exit of vehicles monitoring sheet, attached herein, marked
as Annex “B” , and made an integral part thereto. Such monitoring sheet is
issued by the Gate Security Department of the Subdivision where the
Defendant resides.

COMPULSORY COUNTERCLAIM

1. By reason of the abuse of right committed by the plaintiff and by reason of the
instant precipitate and unfounded suit, the defendant was constrained to hire
the services of a lawyer to defend his rights and interests for a professional fee
of Twenty-Thousand Pesos (P20,000.00) and Three-Thousand Pesos
(P3,000.00) per court appearance.

2. Similarly, the plaintiffs unfounded suit has caused the defendant mental
anguish, wounded feelings, sleepless nights, serious anxieties, and other
similar sufferings for which the defendant claims moral damages of One
Hundred Thousand Pesos (P100,000.00).

PRAYER

WHEREFORE, PREMISES CONSIDERED, it is respectfully prayed to

this honorable court the dismissal of the complaint for lack of merit with costs
against the plaintiff; and that the defendant’s compulsory counterclaim be granted,
i.e., moral damages of One Hundred Thousand Pesos (P100,000.00), attorney’s
fees of Twenty-Thousand Pesos (P20,000.00) and Three-Thousand Pesos
(P3,000.00) per court appearance and costs of suit.

Other reliefs just and equitable under the premises are likewise prayed for.

Catarman, Northern Samar, this 12th day of Decemberr 2020.

By:
________________________
RENZIL BALICUDCUD
Counsel of the Plaintiff
PTR No. xxxx
IBP No. xxxx
Roll No. xxxx
ABC Building, Zone-1, UEP
Catarman, Northern Samar