Republic of the Philippines MUNICIPAL TRIAL COURT IN CITIES 8TH Judicial Region Branch 1 Tacloban City FERNANDO PO,

Plaintiffs, -versusSPOUSES, DINGDONG DANTE AND MARIAN DANTE, Defendants. x------------------------------------------------------------------------------x

ANSWER

DEFENDANT, by its undersigned counsel, in answer to the plaintiff's complaint, respectfully manifests that:

1. It admits the allegations of paragraph 1 thereof only as regards the status and personality of plaintiff and defendants;

2.

It admits paragraph 2, 3 and 4;

3. It has no knowledge or information sufficient to form a belief as to the truth and correctness of paragraph 5, 6 and 7;

4. It cannot either admit or deny the allegations of paragraph8, as the letter allegedly written by the Barangay Chairman informing the defendants could not be found from the records of said defendant;

5. It denies the allegations of paragraph 10, 11 and 12 as mere conclusions of law that are either erroneous or immaterial and irrelevant;

6. It has no knowledge or information sufficient to form a belief as to the truth and correctness of the allegation of paragraph 15 to the effect that plaintiff was never aware or has had knowledge of the contract of exchange in question, and denies the rest of the allegations thereof as erroneous, or immaterial conclusions of law;

AFFIRMATIVE DEFENSES

Defendant further alleges:

1. That by law, the answering defendants is the owner of lot no 3642 under controversy, and plaintiff has no legal right to question such ownership;

2. That plaintiff has no preferential right than defendants to acquire said lot by pre-emption, legal redemption, sale, exchange, or other form of acquisition;

3. That plaintiffs cause of action, if any, has already prescribed'

4. That defendants was ahead of plaintiff in negotiating for the exchange of the lot in dispute.

WHEREFORE, it is respectfully prayed that this case be dismissed, with costs against plaintiff.

Defendants pray for such other reliefs just and equitable under the premises. Tacloban City September 7, 2013.

BETTY BITIFUL Counsel for the Defendants PTR NO. 12345 IBP NO. 67890 Brgy. 109-A Tacloban City Copy Furnished, Atty. Sonia S. Quiero Counsel for the Plaintiff Roll No. 48895 IBP # 6 MCLE Compliance III-0009618