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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT
7TH Judicial Region
Branch 11, Cebu City

Clark Kent
Plaintiff,

- versus - CIVIL CASE NO. 12345

For: _______

Bruce Wayne
Defendant.
x---------------------------x

ANSWER
(With COUNTERCLAIM)

DEFENDANT, by counsel, respectfully states that:

Admissions/Denials

1. He admits the contents of paragraph 1 only insofar as his

personal circumstances but specifically denies the contents insofar as
plaintiff’s personal circumstances for the reason stated in the
Affirmative Defenses below.

2. He admits the contents of paragraph 2 only where it

states that a Contract of Lease was entered into but specifically
denies that the Contract reflects the true intent of the parties as
explained in the Affirmative Defenses below.

3. He admits the contents of paragraph 3 only as to the fact

that demand to vacate was made but specifically denies its contents
as to the truth of the reasons for the letter for lack of knowledge
sufficient to form a reasonable belief as to its truth or falseness.

4. He specifically denies the contents of paragraphs 4 to 6

for the reasons stated in the Affirmative Defenses below.

Affirmative Defense
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1. Defendant reiterates, repleads and incorporates by

reference all the foregoing insofar as they are material and
additionally submit that the Complaint should be dismissed because:

a. Plaintiff has no capacity to sue as it is a foreign

corporation doing business in the Philippines without a license.

b. The Complaint fails to state a cause of action as the

Contract of Lease (ANNEX A) was, before its expiration,
superceded by a Deed of Absolute Sale whereby plaintiff sold to
defendant the parcel of land in question, a copy of which is
attached as ANNEX 1.

Counterclaim

1. Defendant reiterates, repleads and incorporates by

reference all the foregoing insofar as they are material and
additionally submit that he is entitled to relief arising from the filing
of this malicious and baseless suit, as follows:

a. Moral Damages amounting to One Million Pesos

(PHP1,000,000/00) because his name and reputation were
besmirched by this malicious and baseless suit.

b. Attorney’s Fees amounting to One Hundred

Thousand Pesos (P100,000.00) because he was compelled to
secure services of counsel to vindicate his legal rights.

WHEREFORE, Defendant respectfully prays that judgment be

rendered in his favor by dismissing the Complaint and granting
defendant’s counterclaim by awarding defendant: (a) One Million
Pesos as Moral Damages, and (b) Fifty Thousand as Attorney’s Fees.
Other just and equitable reliefs are prayed for.

Quezon City; 13 April 2007.

Maria Makiling
ATTY. MARIA MAKILING
Counsel for the Plaintiff
Comm. No. 12345, 1/21/21, Cebu City
Commission Expires on Dec. 31, 2022
Roll No. 54321
IBP No. 123456, 1/1/21, Cebu City
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PTR No. 12345678, 1/1/21, Cebu City

MCLE Compliance No. 12-12345-12,
1/1/21 until 1/1/23