Professional Documents
Culture Documents
Breach of Contract With Damages Answer Based On New Rules.
Breach of Contract With Damages Answer Based On New Rules.
Breach of Contract With Damages Answer Based On New Rules.
For: ANNULMENT OF
-versus- CONTRACT DUE TO
BREACH OF CONTRACT
MichelleTin Shipping Lines, WITH DAMAGES
Defendan
t.
x- - - - - - - - - - - - - - - -- - - -x
ANSWER
I.
ADMISSIONS
II
SPECIFIC DENIALS
III
AFFIRMATIVE ALLEGATIONS
IV
AFFIRMATIVE DEFENSES
A. Contrary to Plaintiff
Natan’s Allegation,
There Was NO Breach of
Contract on The Part of
Defendant MichelleTin
Shipping Considering
That PLaintifff Natan
Has Not Yet Paid The
Freight For Waybill Nos.
2MC02319062 And
MCT01619057;Thus,
Defendant MichelleTin
Shipping Has The Right
to Withhold The Release
of the Cargoes.
_________________________________
B. Further, Plaintiff
Alejandrino Failed to
Declare Which Debt Her
Payment to Defendant
Moreta ShippingShould
be Applied To
_________________________________
5.17. Under Article 1252 of the Civil Code, a person
who has various debts of the same kind in favor of one
and the same creditor, may declare at the time of making
the payment, wot which of the said debts the payment
must be applied, to wit:
C. In any Case,
Plaintiff Natan Failed
To Make A Demand to
Defendant MichelleTin
Shipping.
__________________________
7.1. Article 2199 of the Civil Code provides for the right
to claim actual damages fro the pecuniary loss on has
suffered, to wit:
PRAYER
WHEREFORE, premises considered, Defendant
DIAMANTE SATOQUIA Shipping respectfully prays that after
due proceedings, the Honorable Court render judgment:
By: