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Answer For Collection of Sum of Money
Answer For Collection of Sum of Money
MARQUS DELANTADO
Plaintiff, CIVIL CASE NO.___________
PATROCENIO ALILAM
AND ALFIANA ALILAM
Defendants
ANSWER
COMES NOW, the defendants by undersigned Counsel and in answer to plaintiff’s
complaint in the above- entitled case, respectfully allege:
2. Defendants specifically deny the allegation in the paragraph 3 of the complaint, the
truth being that, Bimbo Arias and the defendants never seen and talked each other on
July 12, 2014, because the defendants were in Baguio City. As evidenced by the
photocopy of entry/exit of vehicles monitoring sheet issued by the Gate Security
Department of the Subdivision where the defendants reside. (Annex “A”)
3. Defendants specifically deny the allegation in the paragraph 4 of the complaint, the
truth being that, the plaintiff never gave the defendants the alleged amount of Three
Hundred Fifty Thousand Pesos (350,000.00) and that their signatures are forged and
that they did not in fact sign the said document and no contract or even document was
executed for that matter and demand strict proof thereof;
5. Defendants specifically deny under oath in the paragraph 7 and 8 the genuineness and
due execution of the alleged promissory note.
6. Defendants specifically deny the allegation in the paragraph 9 of the complaint, the
truth being that, there was no notice received by the defendants, that their signatures
are forged and that they did not in fact sign the said document and demand strict proof
thereof;
7. Defendants admit the averment in paragraph 10 insofar as the receipt of the demand
letter is concerned and not the contents thereof;
AFFIRMATIVE DEFENSES
1. Signatures of the defendants are forged and that they did not in fact sign the alleged
documents.
2. All statements and comments made by Defendants about Plaintiff were made by the
Defendants with good motive and were fair comments;
3. The Plaintiff has failed to set forth ultimate facts due to inconsistency of the
statements as to the date of the alleged transactions executed between the parties;
4. The Plaintiff has failed to attached documents to prove that the Defendants in fact
were indebted to the Plaintiff;
COUNTERCLAIM
1. That by virtue of this unwarranted and malicious act initiated by the Plaintiff,
Defendants were forced to engage counsel in the sum of Ten Thousand Pesos
(10,000.00)
We, PATROCENIO ALILAM AND ALFIANA ALILAM ,of legal age, Filipino Citizen and
residing at Sampaguita, Solana Cagayan after first having duly sworn to in accordance with law
depose and say:
3. The contents therein are true and correct to the best of our personal knowledge
and based on authentic documents.
IN WITNESS WHEREOF, We have hereunto affixed our signatures this 24th day of
January in Tuguegarao City, Cagayan Philippines.
We certify that on 24th of January 2015, the original of this document was filed with the
Clerk of Court; and, a true and accurate copy of this document was served on the other party
mail, addressed to the following:
PATROCENIO ALILAM
ALFIANA ALILAM
Defendants
EXPLANATION
A copy hereof is served on opposing counsel and the Regional Trial Court by registered
mail, instead of by personal service, due to the urgency of filing the same and due to lack of
messenger of the undersigned counsel for the moment.