REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

7TH JUDICIAL REGION
Branch XIII, Cebu City

RONALD
Plaintiff,
Civil Case No. 35XXX
-versus- For: Collection for Sum of
Money

ARNOLD
Defendant.
X-----------------------------------------X

ANSWER

DEFENDANT ARNOLD, through the undersigned counsel unto this

Honorable Court, hereby respectfully states that:

1) Paragraphs one (1) to six (6) of the Complaint are admitted;

2) Paragraph five (6) to nine (9) of the Complaint are denied insofar
as they allege that the defendant failed to pay the sum of money when in fact
the obligation has been paid already.

By way of special and affirmative defenses, defendant claims that:

1) The obligation has been paid;

2) The Plaintiff and Defendant has not seen each other since the
former has received the full payment;

3) The cause of action has prescribed from its date.

By way of counterclaim, defendant alleges that:

 1) By virtue of this unwarranted and malicious act initiated by the
Plaintiff, Defendant was forced to hire the services of a lawyer to defend his
rights and interests for a professional fee of Twenty thousand Pesos
(₱20,000.00) and Five Thousand Pesos (₱5,000.00) per court appearance;

WHEREFORE, premises considered, it is respectfully prayed to this

Honorable Court the dismissal of the complaint for lack of merit with costs
against the plaintiff; and that the defendant’s compulsory counterclaim be
granted, i.e., attorney’s fees of Twenty-Thousand Pesos (₱20,000.00), and
Five Thousand Pesos (₱5,000.00) per court appearance and costs of suit.

Other reliefs just and equitable under the premises are likewise prayed
for.

Cebu City, Cebu, Philippines, May 30, 2020.

Lorenz Moises Enrick Binghay

Counsel for the Defendant
641 B.M.L Quezon St.,
Mandaue City
REPUBLIC OF THE PHILIPPINES)
CITY OF CEBU )SS.
X-----------------------------------------X

VERIFICATION AND CERTIFICATION

I, Arnold, Filipino, of legal age, single and a resident of Barangay

Tisa, Cebu City, Cebu, Philippines, after duly being sworn to in accordance
with law, hereby depose and say:

That I am the Defendant of the above-entitled case;

That I have caused the preparation and filing of the foregoing Answer
and I have read the allegations therein, and that they are true and correct of
my personal knowledge and belief;

I further certify that I have not commenced any other action or

proceeding involving the same issues before the Supreme Court, Court of
Appeals or any other tribunal or agency and, to the best of my knowledge,
there is no such action or proceeding pending before any tribunal;

If I should thereafter learn that the same or similar action or claim has
been filed or is pending, I shall report that fact within five (5) days therefrom
to this Honorable Court.

IN WITNESS WHEREOF, I have hereunto affixed my signature

this 30th of May 2020, Cebu City, Philippines.

Arnold
Affiant
 SUBSCRIBED AND SWORN to before me, this 29th day of May
2020 at Cebu City, Philippines, affiant having exhibited to me his UMID
bearing No. CRN-22222-00 issued on March 19, 2019 at Cebu City,
Philippines.

Atty. Lorenz Moises Enrick Binghay

Notary Public
Until December 31, 2020
PTR No. xxxx / xx-xx-xx / Cebu City

IBP No. xxxxx /xx-xx-xx / Cebu City

Attorney’s Roll No. xxxxx

MCLE No. xxxxxx, Series of xxxx

Doc. No. ___

Page No. ___
Book No. ___
Series of 2020