Republic of the Philippines

Province of Iloilo
MUNICIPAL TRIAL COURT OF DUMANGAS
Dumangas, Iloilo
Juan Dela Cruz

CIVIL CASE NO.

For: Collection
Plaintif,

-versusAndrew E
Defendant.
x------------------------------------------x

ANSWER TO THE COMPLAINT

COMES NOW defendant Andrew E , through the undersigned counsel
and to this Honorable Court, most respectfully alleges:
1. Defendant denies the allegations in the Promissory note that the
defendant borrowed sum of money to the plaintiff in the amount of
P150,000.00
2. Defendant denies the allegations in promissory note paragraph II.a of the
complaint. The defendant only borrowed sum of money in the amount of
P75,000.00.
3. Defendant denies the allegations contained in paragraph II.b of the
complaint, the truth , the defendant already settled his obligations to the
plaintiff.
4. Defendant admits the allegations in the promissory note of the complaint
but the sum of money which was borrowed by defendant to the plaintiff was
only P75,000 and the defendant was able to settle his obligations last March
21 ,2014 as evidenced by the receipts at the possession of the defendant.

AFFIRMATIVE DEFENSES
12. That plaintiff has no right to collect the amount of P 150,000.00
from the defendant because the debt was only P75,000.00
13. That whatever debt the defendant owes to the plaintiff was only
P75,000.00 and it was already settled.
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PRAYER
WHEREFORE, it is most respectfully prayed that judgment be rendered
in favor of the defendant and against the plaintiff thereby dismissing the
complaint for collection of the sum of money in the amount of P150,000
because the said obligation of the defendant was already settled.
Defendant prays for such other relief and remedies as the Honorable
Court may deem just and equitable under the premises.
Iloilo City Manduriao, Iloilo, Philippines, November 22, 2014, 2014.

ILARDE PENETRANTE AND ASSOCIATES

Counsels for Respondent-Appellant
2nd Floor IBC Building
Cor. Iznart-Delgado Streets, Iloilo City
E-mail address: ipptlaw2002@hotmail.com
Tel. No. (033) 3371154 & (033) 3371146
By:
NAME OF LAWYER
IBP NO. ___________/ Jan. 2, 2014 / ILOILO CITY
PTR NO. ___________/Jan. 3, 2014/ ILOILO CITY
ATTORNEYS ROLL NO. _________
MCLE COMPLIANCE NO. IV-0005183/03/20/12

Copy furnished:
Atty. Douglas Edwin Del Rosario
Counsel for Plaintiffs
Del Rosario Law Office
Door 1, Del Rosario Building
16 Libertad St., Jaro, Iloilo City
__________________________

Registry Receipt No. ____________

Date:

EXPLANATION
(Pursuant to Section 11, Rule 13 of the 1997 Rules of Civil Procedure)
Personal service cannot be effected upon Atty. Douglas Edwin Del
Rosario at Del Rosario Law Office, Door 1, Del Rosario Building 16 Libertad
St., Jaro, Iloilo City due to the distance between the said address and the
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office of the undersigned counsels hence copy of this Answer with

Counterclaim is being served upon him through registered mail with return
card.

Jethro Villaruel

Republic of the Philippines)

City
of
Iloilo ) Sc.
x- - - - - - - - - - - - - - - - - - - - -x

VERIFICATION/CERTIFICATION
I, ______________, of legal age, Filipino, widow, and a resident of Brgy. P.D.
Monfort North, Dumangas, Iloilo, Philippines after having been sworn to in
accordance with law, hereby depose and say:
1. That I am the defendant in the above-entitled case;
2. That I have caused the preparation of the foregoing Answer with Counterclaim;
3. That I have read the allegations and contents thereof and the same are true and
correct based on my personal knowledge and belief and based upon authentic
records;
4. I hereby certify that at the time of the filing of this Answer with Counterclaim, I
have not commenced any other action involving the same issues in the Supreme
Court, the Court of Appeals, or any other tribunal or agency except this Answer with
Counterclaim; that to the best of my knowledge, no such action is pending or was
terminated in the Supreme Court, the Court of Appeals, or any other tribunal or
agency; that if I should learn that a similar action has been filed or is pending in the
Supreme Court, the Court of Appeals, or any other tribunal or agency, I undertake
to report the fact within (5) days therefrom to the court or agency wherein the
original pleading and sworn certification has been filed.
IN WITNESS WHEREOF, I have hereunto set my hand this ____ day of
__________ 2014, in Iloilo City, Philippines.

______________________
Affiant
_________ I.D. No. __________
Issued on ________________
Issued at _______________
JURAT/ NOTARIAL CERTIFICATE
The principal/affiant, whose name and personal circumstances are stated

above appeared in person before me this _____ day of __________ 2014 in the City of
Iloilo City, presented the foregoing verification, signed the same in my presence,
and affirmed or swore under oath to the truth and correctness of the contents or
allegations of the same.
The principal/affiant is personally known to me and she exhibited to me her
Identification Card No. appearing below her signature as competent proof of her
identity and she signed my notarial register.
Doc. No._____;
Page No._____;
Book No._____;
Series of 2014.