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Answer With Cross Claim
Answer With Cross Claim
XIAN LAO,
Plaintiff,
MATEO GO,
Defendant.
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COMES NOW, the defendant, through the undersigned counsel and unto this Honorable
Court, most respectfully avers:
1. That he ADMITS paragraph 2 of the complaint;
2. That he DENIES paragraph 3 of the complaint, the truth being that it was the defendant
JOLO TREVOR who applied for and exclusively benefited from the loan with the plaintiff, answering
defendant acting as mere co-signer in the promissory note to accommodate defendant TREVOR
and to guarantee the loan;
3. That he lacks knowledge or information sufficient to form a belief as to the truth of the
allegations contained in paragraphs 3, 4, and 5 of the complaint and therefore, specifically DENIES
the same;
SPECIAL/AFFIRMATIVE DEFENSES
4. That without the knowledge and consent of answering defendant, the principal condition of the
loan was changed and the term of payment thereof was unreasonably extended by the plaintiff, to
the prejudice of answering defendant;
5. That there was undue delay on the part of the plaintiff in enforcing the payment of the
obligation, and the loan could have been paid immediately at maturity had there been prompt and
timely notification to answering defendant of the non-payment of the loan by defendant TREVOR;
6. That defendant TREVOR should reimburse answering defendant on any and whatever amount
the latter may be held answerable or which he may be ordered or suffered to pay under and by
virtue of the present action in favor of the plaintiff, answering defendant not having benefited
whatsoever from the loan which defendant TREVOR obtained from the plaintiff;
7. That defendant TREVOR should pay plaintiff directly and fully on the amounts claimed by the
latter in its complain he having benefited directly and exclusively from the transaction alleged in the
complaint;
By:
ZEUS MORALES
Roll No. 12345
IBP No. 23456/1-18-2012
PTR. No. 34567/1-18-2012
I, MATEO GO, of legal age, Filipino citizen, single and resident of 234 San Bartolome St.,
Manila, after having duly sworn to in accordance with law, do hereby depose and say that:
1. I am the defendant in the above-entitled case;
2. That I have caused the preparation of the foregoing ANSWER and have read the allegations
contained therein;
3. The allegations in said answer are true and correct of my own knowledge and based on
authentic records;
4. I hereby certify that I have not commenced any other action or proceeding involving the
same issues in any court, tribunal or quasi-judicial agency and, to the best of my knowledge, no
such other action or claim is pending therein;
5. If I should thereafter learn that a similar action or proceeding has been filed or is pending, I
hereby undertake to report that fact within five (5) days therefrom to the court or agency where the
original pleading and sworn certification contemplated herein have been filed;
6. I executed this verification/certification to attest to the truth of the foregoing facts and to
comply with the provisions of Adm. Circular No. 04-94 of the Honorable Supreme Court.
IN WITNESS WHEREOF, I have hereunto affixed my signature this 1st day of October 2012,
in the City of Manila.
MATEO GO
SUBSCRIBED AND SWORN TO before me this 1st day of October 2012, in the City of Manila,
affiant exhibiting to me his SSS ID No. 123456 issued on January 5, 2012.
Copy furnished:
ATTY. JADE GAYONDATO
Counsel for the Plaintiff
Unit 876 Gayondato Bldg.
Pandacan, Manila
JOLO TREVOR
Defendant
123 Singalong St.
Manila
EXPLANATION
Copy of the ANSWER was served by registered mail due to time and distance constraints and
for luck of the undersigned’s staff who can serve the same in person.
ZEUS MORALES