Republic of the Philippines

Sixth Judicial Region

5TH MUNICIPAL CIRCUIT TRIAL COURT
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Plaintiffs,

- versus - Civil Case No. 2022

For Recovery of Ownership and
Possession,

Defendants.
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ANSWER

COMES NOW, Defendants by Counsel, in answer to Plaintiff’s

Complaint, respectfully alleges:

1. Defendants *** are

2. Defendants specifically deny Paragraph 1 of the Complaint for

lack of personal knowledge sufficient to form a belief as to the
truthfulness of the same but admit as to the existence of the
Special Power of Attorney as attached to the Complaint;

3. Defendants admit Paragraphs 2,3 and 4 of the Complaint;

4. Defendants admit Paragraph 5 of the Complaint;

5. Defendants admit Paragraph 6 of the Complaint but specifically

deny the area stated thereat considering that;

6. Defendants admit Paragraph 7 of the Complaint;

7. Defendants admit Paragraph 8 as to the allegation that Plaintiffs’

late father, Emilio, built his house on the portion of Lot 71 but
specifically deny the allegation that Emilio purchased the same
from Miguel for lack of personal knowledge;

8. Defendants admit Paragraph 9 of the Complaint;

9. Defendants specifically deny Paragraph 10 of the Complaint for

lack of personal knowledge sufficient to form a belief as to the
truthfulness of the same or to the existence of the alleged Deed;

10. Defendants admit Paragraphs 11 and 12 of the Complaint but

specifically deny Paragraph 13 for being false and misleading the
truth being …..;

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 11. Defendants specifically deny Paragraph 14 of the Complaint
for being false considering that it …..;

12. Defendants specifically deny Paragraph 15 of the Complaint

for being misleading, false and bereft of any factual basis, the
truth being that:

AFFIRMATIVE DEFENSES

Defendants hereby re-plead the allegations aforementioned and

further aver by way of Affirmative Defenses thus:

1. Defendants asserts that Plaintiffs waited …..;

2. Defendants further assert that Plaintiffs have No Cause of Action

against herein Defendants considering that;

3. The instant Complaint should be dismissed for lack of cause of

action

COMPULSORY COUNTERCLAIM

By way of counterclaim, herein Defendants replead the allegations

stated above and further states that:

1. As a result of the unjustified filing of a baseless, false and flagrant

suit against Defendants which;

2. They were forced to defend their rights and protect their properties
when they were dragged by Plaintiffs in this baseless and
unsupported claim;

3. To in order that the act of the Plaintiff would not be emulated by

others who intent to file flagrant, unjustified and baseless

PRAYER

WHEREFORE, it is respectfully prayed that judgment be rendered:

1. To dismiss the instant Complaint for lack of legal, factual basis

to support the allegations of the Complaint and the Pray sought
in the instant case;

2. To dismiss the Complaint on the ground that Plaintiffs have no

cause of action against herein Defendants;

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 3. To pay Defendants moral damages amounting to Php 50,000.00;

4. To pay Defendants attorney’s fees and cost of suit;

5. To pay Defendants exemplary damages amounting to Php

50,000.00

Other reliefs, just and equitable under the circumstances are

likewise prayed for.

________ for *******. ______.

LEE HYERI.
Counsel for the Accused

Copy Furnished:

LAW OFFICE
Cheongdam St., Agpujong,

EXPLANATION

Copy of the foregoing ANSWER was served to the adverse party

through Counsel by registered mail and LBC Courier personal service not
being practical in view of time, distance and manpower constraints.

LEE HYERI

VERIFICATION