Republic of the Philippines

Municipal Trial Court

Branch 5
Tiwi

Ursula Ditkovich,
Plaintiff,

-versus- CIVIL CASE NO. 13

For: Unlawful Detainer
Mr. Peter Parker,
Defendant,
X—--------------------------------------------------x

Defence Based on Actionable Document

Defendant, by counsel and to this Honorable Court respectfully states:

1. The defendant is of legal age, Filipino citizen, single and a resident of temporary residence in
Coro-coro, Tiwi Albay.
2. Defendant admits that portion of par. 5 of the complainant regarding the written agreement was
indeed established, but denies thereof, for lack of sufficient to form and belief.
3. In the year 2014 the defendant acquired total ownership of the unit through a certification
provided by the plaintiff.
4. The said certification upon purchase of the unit was provided through a letter addressing that
that unit shall be sold with a price of P12,000,000 plus interest.
5. That was paid in full on the day of awarding the unit to the defendant.
6. That due to the unjust and unlawful act of the plaintiff by revising the contract to lease,and
forcefully vacating with force within the premise of dwelling plus destruction to personal property,
breach the original agreed terms without consent and trespassing.

WHEREFORE, it is respectfully prayed that judgement be rendered against the plaintiff and to pay the
defendant the sum of 3,000,000 plus interest of 12% from the date the instrument is paid in full and attorney’s
fee in the amount of 1,000,000 and cost of the suit.

Other equitable reliefs are likewise prayed for.

This 2nd day of March 2017 Tiwi

Matthew Murdok
Attorney for the Defendant
PTR No. 188993794: 1-05-09: BC
IBP No, 77667: 1-05-09: BC
Roll No. 43422: 5-11-18 : Manila
Rm. 3 2/F Tiwi Mini Mall
123 Tigbi, Tiwi