REPUBLIC OF THE PHILIPPINES

Fourth Judicial Region

MUNICIPAL CIRCUIT TRIAL COURT
Taal Batangas

SUSAN ROXAS
Plaintiff,

Civil Case No. 143

For: Unlawful Detainer
SPOUSES JUAN and STELLA BERNABE
Defendants.
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ANSWER

DEFENDANTS, by counsel, and unto this Honorable Court, most

respectfully allege:
1. Defendants admit the allegations contained in paragraphs 1, 2 and 3;
2. Defendants deny the allegation contained in paragraph 4 in that there
are rentals paid for the use and occupation of the mentioned property
which started since the acquisition of the herein plaintiff of the
property on August 08, 2012. The monthly rental paid amounted to
one thousand five hundred pesos (Php 1,500.00). Attached herein
was the Acknowledgement Receipt as Annex “1”;
3. Defendants admit paragraph 5 but without prejudice to the advance
rental payment made which is until December 31, 2020 as evidenced
in the Acknowledgement Receipt attached in this answer;
4. Paragraphs 6 and 7 are also admitted but demands of the plaintiff
was not heeded due to the advance rental payment made;
5. Defendants deny paragraph 8, the truth being stated in the affirmative
defenses;
 6. Paragraph 9 of the Complaint is denied for lack of knowledge and
information sufficient to form a belief as to the veracity or falsity of the
alleged amounts of attorney’s fees agreed upon between the plaintiff
and her lawyer;
7. Defendants admit the allegations contained in paragraph 10;
8. By reason of the abuse of right committed by the plaintiff and by
reason of the instant precipitate and unfounded suit, the defendant
was constrained to hire the services of a lawyer to defend his rights
and interests for a professional fee of P20,000.00 plus P3,000.00 per
court appearance.

PRAYER
WHEREFORE, premises considered, it is most respectfully prayed of
this Honorable Court that after due notice and hearing, judgment be
rendered in favor of Defendants:

1. That the case be dismissed for lack of cause of action;

2. To pay the compulsory counterclaim amounting to attorney’s fees of
P23,000.00.

Other reliefs just and equitable under the premises are likewise
prayed for.
Batangas City, Philippines, October 5, 2020.

ATTY. HENERAL DOUGLAS

Counsel for Defendant
3rd Floor ABC Building, Rizal Ave,
Batangas City, Batangas
Roll of Attorneys No. 54321
PTR No. 7654321/Batangas City/01-05-19
 IBP Lifetime No. 123456/Batangas City
MCLE Compliance No. V-0012345;08-12-19
TIN: 136-149-961-000