Republic of the Philippines

REGIONAL TRIAL COURT

Ilocos Sur
Second Judicial Region
Vigan City, Ilocos Sur

AA and BB
Plaintiff, CIVIL CASE NO.

- versus – FOR: COLLECTION OF SUM OF MONEY

WITH DAMAGES

CC and DD
Defendants

ANSWER

COMES NOW, the defendants by undersigned Counsel and in answer to

plaintiff’s complaint in the above- entitled case, respectfully allege:
1. Defendants admit the averment in paragraphs 1,2 and 3 of the complaint;
2. Paragraph 4 of the complaint denied, the truth that the defendant never
agreed for the price of Thirteen Million One Hundred Ninety Two Thousand
Five Hundred fifty Two Pesos and sixty centavos (13,192,552.60) and that
the contract was entered into by reason of the misrepresentation of
statement during contract negotiations and/or formation, rendering the
contract invalid.
3. Defendants admit the averment in paragraph 5,6 and 7 of the complaint;
4. Paragraph 8 denied, the truth that on June 15, 2017, plaintiff and
defendant never seen and talked to each other;
5. Paragraphs 9 and 10 of the complaint denied for lack of knowledge or
information sufficient to form a belief as to the veracity or falsity thereof,
the allegations known only to the plaintiff;
6. Paragraphs 11 and 12 of the complaint admitted;
7. Paragraph 13 of the complaint denied, the fact that the contract is not valid
and binding due to the misrepresentation of facts which caused the
defendant to enter into the contract;
8. Defendant denies the averment in paragraphs 14 and 15 of the complaint,
the truth that the defendant did not signed the accomplishment report and
that his signature was forged;
 9. Defendant denies paragraphs 16, 17 and 18 insofar as it alleges that the
defendant owes the plaintiff a sum of money and that demand was made
and such demand falls unheeded;

AFFIRMATIVE DEFENSES
Having answered the Complaint, the Defendants, CC AND DD, assert the following
enumerated Affirmative Defenses.

1. The defendant avers that the contract is null and void for having entered into by
misrepresentation of statements.

2. Signatures of the defendants are forged and that they did not in fact sign the alleged
documents.

3. All statements and comments made by Defendants about Plaintiff were made by the
Defendants with good motive and were fair comments;

4. The Plaintiff has failed to set forth ultimate facts due to inconsistency of the statements as
to the date of the alleged transactions executed between the parties;

5. The Plaintiff has failed to attached documents to prove that the Defendants in fact were
indebted to the Plaintiff;

COUNTERCLAIM

Defendants, CC AND DD alleges;

1. That by virtue of this unwarranted and malicious act initiated by the Plaintiff,
Defendants were forced to engage counsel in the sum of Ten Thousand Pesos
(10,000.00)

WHEREFORE, it is respectfully prayed that the complaint be dismissed and

defendant be awarded the amount of Twenty Thousand Pesos (20,000.00)

Other just and equitable reliefs are likewise prayed for.

ATTY. JOSELLE J. REYES

Vigan City, Ilocos Sur City Attorney’s Roll No. 54654
IBP No. 927307, Ilocos Sur 1-2913
PTR No.3202399, Vigan City, Ilocos Sur, 1-21-13
MCLE Compliance No. 1110016263, 05-31-10
 VERIFICATION/CERTIFICATION

We, CC AND DD, of legal age, Filipino Citizen and residing at Brgy. X, Vigan City,
Ilocos Sur, Philippines after first having duly sworn to in accordance with law depose
and say:

1. We are the defendants in the above- entitled case

2. We have caused the preparation of the foregoing complaint
3. The contents therein are true and correct to the best of our personal
knowledge and based on authentic documents.
4. We hereby certify that we have not commenced any action or proceeding
involving the same issue in any tribunal or agency, to the best of our own
knowledge, no such action or proceeding is pending in any other tribunal or
agency and should We thereafter learn that a similar action or proceeding has
been filed or is pending in Court, we will undertake to report such fact within
five (5) days therefrom to the court wherein this Petition and this certification
have been filed.

IN WITNESS WHEREOF, We have hereunto affixed our signatures this 14th day
of November 2020 in Vigan City, Ilocos Sur, Philippines.

CC DD
Affiant Affiant

SUBSCRIBED AND SWORN to before me this 14th day of November 2020 in

Vigan City, Ilocos Sur, Philippines

ATTY. JOSELLE J. REYES

Vigan City, Ilocos Sur
Attorney’s Roll No. 54654
IBP No. 927307, Ilocos Sur 1-2913
PTR No.3202399, Vigan City, Ilocos Sur, 1-21-13
MCLE Compliance No. 1110016263, 05-31-10
 CERTIFICATE OF SERVICE

We certify that on 14th of January 2020, the original of this document was filed
with the Clerk of Court; and, a true and accurate copy of this document was served on
the other party mail, addressed to the following:

TO: MNO
Vigan City, Ilocos Sur, Philippines

CC

DD
Defendants

EXPLANATION

A copy hereof is served on opposing counsel and the Regional Trial Court by
registered mail, instead of by personal service, due to the urgency of filing the same
and due to lack of messenger of the undersigned counsel for the moment.

JOSELLE J. REYES
Counsel for Defendants