REPUBLIC OF THE PHILIPPINES REGIONAL TRIAL COURT SIXTH JUDICIAL REGION BRANCH 33 ILOILO CITY ANTONETTE C. CARO Plaintiff, CIVIL CASE NO. !"#$ %&'()*)%
FOR+ COLLECTION OF SU OF ONEY
JOHN REY D. ABADA D'f'n-ant, %%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%% ANS/ER
NO/ COES the defendant in the above entitled case, and to this
Honorable Court most respectfully alleges: 1. Defendant Defendant admits admits the averment averment in in paragraph paragraph 1, 2 and 3 of the the complaint; 2. Defendant Defendant specifical specifically ly denies the the allegation allegation in paragraph paragraph of the complaint, the truth being that the obligation has been paid already; 3. Defendant Defendant has no !no"le !no"ledge dge or information information to to form a belief belief as to the truth of the averment in paragraphs #,$ and % of the complaint; &y "ay of special and affirmative defenses, defendant avers: 1. 'hat the the obligat obligation ion has has been paid paid;; 2. 'hat the defendan defendantt had purchased purchased said said land from plaintiff plaintiff and and paid said promissory notes; 3. 'hat the the cause cause of action action has prescribed. prescribed. 1
&y "ay of counterclaim, defendant alleges: 1. 'hat by virtue of this un"arranted and malicious act initiated by the plaintiff, defendant "as forced to engage counsel in the sum of (1),))).)).
WHEREFORE, it is respectfully prayed that the complaint be
dismissed and defendant be a"arded the amount of (#,))).)). *ther e+uitable reliefs are li!e"ise prayed for. loilo City, (hilippines, -anuary 1), 2)1%
SHANE ARIE BELLOGA % EDROSOLANO
Counsel for the Defendant rguelles &ldg., -aro, loilo City /oll 0o.: 11)2 ('/ 0o.: 11123# )$3)2)1$ loilo City &( 0o.: 1%$1 )$3)2)1$ loilo City 4C56 Compliance 0o.: ##13 ))#2)1$
VERIFICATION AND CERTIFICATION
2
, JOHN REY D. ABADA, of legal age, married, 7ilipino and a resident of &rgy. &uhang., -aro, loilo City, under oath depose and state that: a8 am the defendant in the above captioned case; have caused the preparation of the foregoing ans"er; b8 have read the allegations contained therein; and c8 certify that they are all true and correct of my personal !no"ledge or based on authentic records. n "itness "hereof, have hereunto set my hand this 1) th day of -anuary 2)1% at loilo City, (hilippines. JOHN REY D. ABADA SUBCRIBED AND S/ORN TO before me this 1)th day of
-anuary 2)1% in loilo City, (hilippines, affiant e9hibiting to me her (/C .D. no. 123#$ issued in loilo City on -une 3), 2)1$ and valid until -une 3), 2)1.
SHANE ARIE BELLOGA0EDROSOLANO
0otary (ublic for the City (rov. of loilo ntil December 31, 2)1 rguelles &ldg., -aro, loilo City /oll 0o.: 11)2 ('/ 0o.: 11123# )$3)2)1$ loilo City &( 0o.: 1%$1 )$3)2)1$ loilo City 4C56 Compliance 0o.: ##13 ))#2)1$ Doc. 0o. (age 0o. &oo! 0o.
3
4
