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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT


CITY OF MALAYBALAY
BRANCH 9

MERIAM PIYA VILLAR


Plaintiff,
CIVIL CASE No. 82843
ANSWER OF DEFENDANT
TEOFISTO ENRILE SOTTO
TO COMPLAINT OF
PLAINITIFF MERIAM PIYA
VILLAR

-versusTEOFISTO ENRILE SOTTO


Defendant.
x-----------------------------------x

ANSWER
COMES NOW, the defendant, Teofisto Enrile Sotto, who answers the unlawful
detainer complaint of Plaintiff, Meriam Piya Villar, as follows:
1.
2.

3.
4.

5.

6.
7.

8.

9.

Admits that the plaintiff, MERIAM PIYA VILLAR, is of legal age, Filipino citizen,
single, with residence and postal address at Claro M. Recto Street, Malaybalay City;
Admits that the defendant, TEOFISTO ENRILE SOTTO, is of legal age, Filipino
citizen, single, with residence and postal address at Casisang, Malaybalay City, where
may be served with summons and other court processes therein by this Honorable
Court;
Admits that the plaintiff is the legal owner of a land over which an apartment had
been constructed located 654 San Pedro Street, Manila;
Admits that by virtue of a contract of lease, the plaintiff leased unto the defendant
the aforesaid apartment for a consideration of P8,000.00 a month as rental to be paid
within the 15th day of the month starting April 15, 2012;
Admits that such Contract of Lease as Annex A as attached thereto stipulates
that any violation in the forgoing provisions shall subject the contract to be terminated
and the lessee to vacate the premises;
Admits that the defendant failed to pay the agreed rental for eight months
starting May 15, 2013 up to the present;
Admits that on December 10, 2013, the plaintiff sent a letter of demand to vacate
the apartment which was received by the defendant as shown in the registry return
receipt hereto attached as Annex B and despite the said letter of demand which was
followed up by oral demands, the defendant failed to pay the agreed amount of rentals
and to vacate the apartment;
Admits that on January 5, 2014, they came to an understanding that the debt of
the plaintiff from the defendants uncle will be cancelled on the fact that the defendants
unpaid rentals will be considered paid by the plaintiff;
Denies that by reason of failure of the defendant to vacate the premises and to
pay the unpaid rentals, the defendant is to vacate the subject premises, to pay the
amount of P5,000.00 per month as compensation for the reasonable use of the subject
premises until they finally vacate the said premises, and to pay the plaintiff the cost of
the suit;
10.
This defendant avers that such agreement should be upheld by the
plaintiff and that is such agreement is not considered the plaintiff is guilty of the Doctrine
of Unclean Hands and is entitled to no relief whatsoever.

WHEREFORE, defendant Teofisto Enrile Sotto pray that plaintiff Meriam Piya Villar take
nothing from her compliant dated February 28, 2014.
Dated 10th day of March 2014.

VERIFICATION

I, TEOFISTO ENRILE SOTTO, am a defendant in the above-entitled action. I have read


the foregoing anser and know the contents thereof. The same is true of my own
knowledge, except as to those matters which are therein alleged on information and
belief, and as to those matters, I believe it to be true.
I declare under penalty of perjury that the foregoing is true and correct and that this
declaration was executed at Malaybalay City, Bukidnon.

Dated 10th day of March 2014.


SHARMILAH G. SUAREZ
Counsel for the Defendant
Roll of Attorney No. 54321
IBP No. 98765/03-10-13/Manila
PTR No. 34567/12-22-11/Manila

Doc. No. ________


Page No. _______
Book No. _______
Series of 2012.

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