CHRISTELLE DIVINAGRACIA

JD 3B

Republic of the Philippines

Region VI
Regional Trial Court Iloilo City
Branch 32

JOLINA RIZON
Plaintiff,
Case No. 1162333
For: Sum of Money

- versus –

MARICEL CARLOS,
Defendant.
X------------------------------X

ANSWER

DEFENDANT MARICEL CARLOS, by undersigned counsel, unto this Honorable Court

most respectfully states:

1. Paragraphs one (1) and two (2) 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 of the plaintiff:

SPECIAL AND AFFIRMATIVE DEFENSES

1. That the complaint states no cause of action;
2. That the defendant has paid the money owed to the complainant.
3. That in order to protect the rights and interests of the defendants, they solicited the
services of counsel for which they obliged themselves to pay the sum of Fifteen Thousand
Pesos ( P15,000.00) as acceptance for attorney’s fee plus Five Thousand Pesos (
P5,000.00 ) per appearance in court of counsel and they incurred and will incur the sum
of Ten Thousand Pesos ( P10,000.00) as litigation expenses for which these amounts
should be reimbursed by the plaintiff; and.
4. That by reason of the filing of this instant action, the defendants had suffered mental
anguish, wounded feelings, sleepless nights, serious anxities and other similar sufferings
for which the same could be atoned by condemning the plaintiff to pay them the sum of
Twenty Thousand Pesos ( P20,000.00 ) as moral damages and to give a lesson to the
plaintiff and to deter others from doing the same act, a further sum of Ten Thousand
Pesos ( P 10,000.00 ) as sundry litigation expenses5. Defendant received the final
demand letter via LBC on January 31, 2019, however, she did not pay.
CHRISTELLE DIVINAGRACIA
JD 3B

PRAYER
WHEREFORE, premises considered, it is most respectfully prayed that judgment issue
in favor of the defendants and against the plaintiff, the following:
a. Ordering the dismissal of the complaint with costs against the plaintiff;
b. Ordering the plaintiff to pay the defendants the following sums: Twenty Thousand
Pesos (P20,000.00 ) as moral damages; Ten Thousand Pesos (P10,000.00 ) as
exemplary damages; Fifteen Thousand Pesos ( P15,000.00) as acceptance for attorney’s
fee plus Five Thousand Pesos ( P5,000.00 ) per appearance in court of counsel and Ten
Thousand Pesos ( P10,000.00) as sundry litigation expenses; and
c. Such other reliefs and remedies just and equitable in the premises. Other relief and
remedies are likewise prayed for.

11 September 2019, Iloilo City.

LOUIE PEREZ
Counsel for Defendants
Roll of Attorney No. 56567
IBP O.R. No. 654321 (11/20/15)
PTR O.R. No. 0134876(10/10/14)
Ground Floor ALS Bldg.
Ortiz St., IloiloCity
Telephone No. (033) 866-3716
E-mail address thefirm@PerezLawFirm.ph

VERIFICATION AND CERTIFICATION

I, MARICEL RAMOS, Filipino, of legal age, resident of Mandurriao Iloilo City, Philippines,
under oath, hereby depose and say: I am the defendant in the above-entitled case; that I
have caused the preparation and filing of the foregoing answer; that I have read and
understood all the allegations contained therein and that the same are true and correct to
the best of my knowledge and belief.

Iloilo City, September 11, 2019.

MARICEL RAMOS
Defendant

SUBSCRIBED AND SWORN to before me this 11th day of September 2019 in Iloilo City,
Philippines.
NOTARY PUBLIC
Doc. No.:
Page No.:
Book No.:
Series of 2019