REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

TENTH JUDICIAL REGION
BRANCH 30,
SURIGAO DEL NORTE

JUANA DELA CRUZ,

Plaintiff,
Civil Case No. 123456
- versus -
FOR: Collection of Sum of Money
PEDRO A. TAN,
Defendant,
x - - - - - - - - - - - - - - - - - - - -x

ANSWER

NOW COMES the defendant in the above entitled case, and to this
Honorable Court most respectfully alleges:

Defendant admits the averment in paragraph 1 and 2 of the complaint;

1. Defendant specifically denies the allegation in paragraph 3 of the

complaint 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 hereinbelow;

1. Paragraphs 4 and 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;

By way of special and affirmative defenses, defendant avers:

1. The Plaintiff never gave the defendant the alleged amount of Four
Hundred Thousand Pesos (₱400,000.00); that Defendant did not sign
the alleged promissory note; and that Defendant’s signature is forged;

2. On August 25, 2019, the Defendant and the Plaintiff did not see each
other because the former was having a vacation in Manila as
evidenced by the photocopy of the plain ticket, attached herein,
marked as Annex “A”, and made an integral part hereto.

Other equitable reliefs are likewise prayed for.

Surigao City, Philippines, December 14, 2020

1
 ATTY. LUCIO A. TAN
Counsel for the Defendant
TAN LAW OFFICE
Rizal Street, Brgy Washinton, Surigao City
Roll No. 654321
PTR No 333333, May 25, 2019
IBP No. 444444 Surigao City May 25, 2019
MCLE Compliance No. 9876543

VERIFICATION

I, PEDRO A TAN, of legal age, Filipino, married, and a resident of

#125 Lopez Jaena Street, Brgy. Washington, Surigao City, after being sworn
in accordance with law, hereby depose and state that:

a) I am the defendant in the above captioned case; I have caused

the preparation of the foregoing answer;

b) I have read the allegations contained therein; and

c) I certify that they are all true and correct of my personal

knowledge or based on authentic records.

In witness whereof, I have hereunto set my hand this 14th day of

December 2020 at Surigao City, Philippines.

PEDRO A TAN
Affiant
PRC I.D. no. 123456

  

 SUBCRIBED AND SWORN TO before me this 14th day of

December 2020 in Surigao City, Philippines, affiant exhibiting to me her
PRC I.D. no. 123456 issued in Surigao City on June 30, 2013 and valid
until June 30, 2020.

ATTY. LUCIO A TAN

Notary Republic for and in the city of
Surigao
2
 TAN LAW OFFICE
Rizal Street, Brgy Washinton, Surigao City
Roll No. 654321
PTR No 333333, May 25, 2019
IBP No. 444444 Surigao City May 25, 2019
MCLE Compliance No. 9876543

Copy furnished:

ATTY. JEFFREY H. BORJA

Counsel for Complainant
#051 Narciso Street, Brgy. Taft, Surigao City
Roll of Attorney No. 01234
PTR No. 25643, Surigao City, January 10, 2019
IBP No. 24358, Surigao City, January 4, 2019
MCLE Compliance No. 012345

3
 ANNEX A

CEBU PACIFIC AIR

BOARDING PASS No. 123456

PASSENGER: PEDRO A. TAN

FLIGHT No. PR 123 BXU-MNL
DEPART: 08:00 08/24/2019
ARRIVE: 09:45 08/24/2019

CEBU PACIFIC AIR

BOARDING PASS No. 654321

PASSENGER: PEDRO A. TAN

FLIGHT No. PR 123 MNL-BXU
DEPART: 08:00 08/28/2019
ARRIVE: 09:45 08/28/2019