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Answer For Collection of Sum of Money With Damages
Answer For Collection of Sum of Money With Damages
ANSWER
1. Paragraphs one (1) and two (2) of the Complaint are admitted;
2. Paragraphs three (3) to five (5) of the Complaint are denied for
lack of knowledge or information sufficient to form a belief as to the
veracity or falsity thereof, the allegations therein being matters
known only to and are within the control only of the plaintiff;
1. On May 25, 2015, the Defendant and the Plaintiff did not see
each other because the former was having a vacation in Baguio
City as evidenced by the photocopy of entry/exit of vehicles
monitoring sheet, attached herein, marked as Annex “A”, and made
an integral part hereto. Such monitoring sheet is issued by the
Gate Security Department of the Subdivision where the Defendant
resides.
COMPULSARY COUNTERCLAIM
PRAYER
By:
TRIVEN P. CASTILLO
Roll of Attorney No. 45969
PTR No. 123456; 01-02-01 / Lipa City
IBP Life Member Roll No. 445789/07-08-01 / Lipa City
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Complaint
MCLE Compliance No. III-897656 / 12-10-01
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Complaint
I, HAZEL ANNE M. MANALO of legal age, Filipino, married,
and a resident of Blk. 3, Sta. Cruz St., United Homes Subdivision,
Brgy. 2, Lipa City, Batangas, after having been duly sworn to in
accordance with law, hereby depose and state that:
TRIVEN P. CASTILLO
Notary Public
Valid Until December 31, 2015
Roll of Attorney No. 45969
PTR No. 123456; 01-02-01 / Lipa City
IBP Life Member Roll No. 445789/07-08-01 / Lipa City
MCLE Compliance No. III-897656 / 12-10-01
Doc. No.: 49
Page No.: 8
Book No.: II
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Complaint
Series of 2015
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Complaint