Republic of the Philippines

MUNICIPAL TRIAL COURT

Fift Judicial Region
Daraga Albay

KIRSTEN C. SAZON
Plaintiff,
CIVIL CASE
NO.54304
for Collection of
Sum Money
based on
Bouncing
Checks with
Damages

-versus-

GABRIELLE CJ LAGRIMAS
Defendant,

x- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - x

ANSWER

DEFENDANT, through undersigned counsel, before this Honorable Court,

most respectfully states THAT:

1. Defendants admits the the avernment in paragraph 1, 2, 3, 4 of the

complaint.

2. Defendant denies the allegation in paragraph 5 and 6. Defendant has

no knowledge or information to form belief in the mentioned
paragraphs since no notice of dishonored was presented to the
defendant.

3. Defendant specifically denies the allegation in paragraph 7 and 8 of

the complaint, the truth being that the obligation has been paid already
so the amount covered by the checks were already paid.

By way of special and affirmative defenses, defendant avers:

1. That the obligation has been paid;

2. That no notice of dishonored of the check was presented to the
defendant;
 COUNTERCLAIM

ANSWERING defendant repealeds all the foregoing allegations and

by way of counterclaim, further states THAT:

1. Due to this unwarranted and malicious act, the plaintiff and

defendant were forced to hire counsel in the amount of
P85,000.00;

2. As a result of plaintiff's unjustified and premature lawsuit

against herein defendant, she suffered and continues to suffer
mental anguish, shock, sleepless nights, wound feelings, and
severe anxiety for which she should have to pay P25,000.00 as
moral damages;

3. As for the plaintiff's bad faith in forcing the defendant to litigate

so as to prevent others from replicate plaintiff's fraudulent,
reckless, oppressive, and malevolent acts, defendant seeks the
same amount of P20,000.00 in exemplary damages.

WHEREFORE, it is respectfully prayed that the complaint be

dismissed and defendant be awarded the amount of P10,000.00.

Other equitable reliefs are likewise prayed for.

Daraga Albay, Philippines, June 21,2024

AYA MARQUEZ- CORTEZ

Counsel for the Defendant
Yap Bldg., Rawis, Legazpi City
Roll No.: 12468
PTR No.: 1112345 06-27-2019 Legazpi City
IBP No.: 176184 06-27-2017 Legazpi City
MCLE Compliance No.: 547623 05-18-2017
 CERTIFICATION OF NON-FORUM SHOPPING

I, GABRIELLE CJ LAGRIMAS, of legal age, single, Filipino and a

resident of Mutya Street, Barangay Tagas, Daraga Albay, under oath
depose and state that:

a) I am the defendant in the above captioned case; I have caused the

preparation of the foregoing answer;

b) I have read the allegations contained therein; and

c) I certify that they are all true and correct of my personal knowledge
or based on authentic records.

IN WITNESS WHEREOF, I have hereunto set my hand this 21st

day of June 2024 at Daraga Albay, Philippines.

GABRIELLE CJ LAGRIMAS
Defendant

SUBCRIBED AND SWORN to before me this 21st day of June

2024 in Daraga Albay, Philippines, affiant exhibiting to me his valid
national I.D. no. 657834 issued in Daraga Albay on February 16,
2021.

ELLA MARIE SANTOS

Notary Public for the City & Prov. of Legazpi
Until December 31, 2025
Liberty Bldg., Sagpon, Legazpi City
Roll No.: 35237
PTR No.: 389726 06-30-2016 Legazpi City
IBP No.: 291238 06-30-2016 Legazpi City
MCLE Compliance No.: 55532 05-23-2016

Doc. No.
Page No.
Book No.
Series of 2017