Republic of the Philippines

Fifth Judicial Region

MUNICIPAL TRIAL COURT
PILAR, SORSOGON

RICHARD LOBRIGO LLONA,

Protestant,

-versus. ELECTION CASE NO.553

For: ELECTION CASE

OTILES LOVEDORIAL BEQUILLOS,

Protestee,
x-----------------------------------------------x

ANSWER

PROTESTEE, through the undersigned counsel before this Honorable Court,

most respectfully denies that:

1. Protestee denies all the allegations against him, that such allegations were
being hypothetically made and purely fabricated by Protestant to nullify the
proclamation as the re-elect Barangay Captain of Sacnangan, Pilar Sorsogon.

2. That none of the allegations stated in paragraph 7 of the complaint are true
accorded to the best of his knowledge; there being no evidence to show
conspiracy with the BET transpired.

3. That there was being neither fraud nor deceit based on the belief of the
Protestee as to the deliberate reduction of votes garnered in favor of him
appearing in election returns as he completely relied on the faithful exercise
of work of the Board of Canvassers.

4. That the Protestee firmly believes that he is the rightful winner and duly
elected Barangay Captain of Barangay Sacnangan, Pilar, Sorsogon
evidenced by the voice of the people of the said barangay as tabulated by the
Board of Canvassers, hence, it is not necessary to recount the votes, re-
appreciate the ballots and re-compute the number of votes.

5. Based on this lack of information or belief, Protestee denies the remaining

and all other allegations.

6. That if any liability exists on the part of the Protestee, such liability is to be
completely indemnified by the Protestant.

1
 PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of this

Honorable Court that:

a. Judgment be rendered in favor of the Protestee and,

b. The Protestant shall be ordered to pay Protestee actual, moral damages and
Attorney’s fees and other relief which are just and reasonable are similarly
prayed for.

Other relief and remedies as may be deemed just and equitable under the
premises are likewise prayed for.

Atty. Arnulfo Cabredo

Counsel for the Protestee
MCLE Certificate No.
IBP No. 672388, 1/6/2015, Davao City
PTR No. 97328, 1/8/2015
Roll No. 8888
Room 45 Fuentes Building, Jasmin St. Davao City

(sample only)

JURAT

SUBSCRIBED AND SWORN to before me this ___ day of May, 2018 by OTILES
LOVEDORIAL BEQUILLOS, known to me personally, who is the same person who
signed before me the foregoing document and who acknowledged before me that he
executed the same voluntarily.

ATTY. ARNULFO CABREDO

Counsel for the Protestee
Until July 9, 2016
MCLE Certificate No. V-09678
IBP No. 672388, 1/6/2015, Davao City
PTR No. 97328, 1/8/2015
Roll No. 8888
Room 45 Fuentes Building, Jasmin St.
Davao City