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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT


7th Judicial Region
Branch 26, Cebu City

Brad Pitt,
Plaintiff,

CIVIL CASE NO. 457893


FOR: SUM OF MONEY
-versus-

Angelina Jolie,

Defendant,

x x

ANSWER WITH SPECIAL AND AFFIRMATIVE DEFENSES


AND COUNTERCLAIM

NOW COMES the defendant in the above-entitled case, and to this


Honorable Court most respectfully alleges:

1. Defendant admits that on April 10, 2014, she borrowed from the
plaintiff the amount of P350,000 but was only forced to sign the
agreement relative to the loan and is not amenable to the high
interest rate of 4% and that she had no authority to use ’s property.

2. Defendant specifically denies appearing before notary public


James Bond nor acknowledging before him that the execution of
the agreement was her free and voluntary act.

By way of special and affirmative defenses, defendant avers:

1. That the contract signed by the defendant is unconscionable. The


stipulation of 4% interest per month is excessive and grossly unfair
which is contrary to law, morals, good customs, public order, or
public policy making it null and void.
2. That the obligation of the defendant is only in the amount of
Eighty Thousand Pesos (P350, 000) not P800, 400.

3. That the plaintiff took advantage of defendant’s situation and


made her enter into the contract against her will.

4. That the defendant did not appear before notary public James
Bond nor acknowledging before him that the execution of the
agreement was her do free and voluntary act making the
execution of said agreement null and void.

By way of counterclaim, defendant alleges:

1. That because of this malicious act by the plaintiff, the defendant


suffered sleepless nights, mental anguish, fright, serious anxiety,
besmirched reputation, wounded feelings, moral shock, social
humiliation, unjust vexation and other moral sufferings.

2. That by virtue of this unwarranted act initiated by the plaintiff,


defendant was forced to engage counsel in the sum of P30, 000
with a fee of P2, 000 per appearance.

WHEREFORE, it is respectfully prayed that the complaint be dismissed and


defendant be awarded the amount of P150, 000.00 for moral and exemplary
damages with attorney’s fees and litigation expenses.

Other equitable reliefs are likewise prayed for.

Cebu City, Philippines, May 18, 2021.

ATTY. PAULINO LABRADO


Counsel for the Defendant
Attorney’s Roll No. 54654
IBP No. 927307, Cebu City
PTR No. 3202399, Cebu City
MCLE Compliance No. 45687
Labrado Law Office
Osmena Blvd, Cebu City
VERIFICATION AND CERTIFICATION

I, ANGELINA JOLIE, Filipino of legal age, married, and residing at Brgy. Pardo,
Cebu City, Philippines after being sworn according to law hereby depose and
state that:

1. I am the defendant in the above titled complaint;


2. That the Corporation has duly authorized me to represent its interest in
the above titled complaint.
3. I have not commenced any action or proceeding involving the same
issues in the Supreme Court, Court of Appeals, or any tribunal or
agency; that to the best of my knowledge, no such action or
proceeding is pending in the Supreme Court, the Court of Appeals or
any Tribunal or agency.

IN WITNESS WHEREOF I have hereunto affixed my signature in this document


this 1st d a y of February, 2021, here at Cebu City, Philippines

ANGELINA JOLIE
DEFENDANT

SUBSCRIBED AND SWORN to before me, in the City of Cebu, this 1st day of February 2021
at Cebu City, Philippines by Angelina Jolie with PRC ID No. 003822 and expiration date on 07/03/2025,
a valid government identification card as her competent evidence of identity.

ATTY. PAULINO LABRADO


Notary Public
Attorney’s Roll No. 54654
IBP No. 927307, Cebu City
PTR No. 3202399, Cebu City
MCLE Compliance No. 45687
Labrado Law Office
Osmena Blvd, Cebu City

Doc. No. 4:
Page No. 1:
Book No. 1:
Series of 2022:

COPY FURNISHED:

GAMAYON LAW OFFICE


Atty. Jeanne Aurice C. Gamayon
Counsel for the Plaintiff
Quiot, Cebu City

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