REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

NATIONAL CAPITAL JUDICIAL REGION
BRANCH 101, QUEZON CITY


ABC CORPORATION
Plaintiff,
-versus- Civil Case No. L-00-238498
JUAN W. DELA CRUZ For: Ejectment
Defendant.
x ------------------------------------- x

C O U N T E R C L A I M

COMES NOW, Defendant Juan W. Dela Cruz, through the undersigned
counsel, unto this Honorable Court, respectfully states:

1. Defendant admits Paragraphs 1, 2 and 3 of the Complaint;

2. Defendant denies Paragraph 4 of the complaint for being false and devoid of
truth, the truth of the matter shall be herein after stated:

3. Defendant legally occupied the Condominium unit registered under QRS
Condominium, located at 1230 Emerald Avenue, Ortigas Center, Pasig City.
Defendant was informed about the terms and agreements of the lease of the
unit subject herein; Defendant sent a Letter of Intent
1
and Notarized Lease
Agreement
2
, to the former General Manager of ABC Corporation, Mr. Raul
Roxas;


1
Annex 1 (Copy of Letter of Intent)
2
Annex 2 (Copy of Notarized Lease Agreement)
4. Defendant claims that on July 08, 2014, defendant met Mr. Raul Roxas at SM
Megamall to signed a pro-formal Notarized Lease Contract
3
that, according to
Mr. Roxas is pre-signed by ABC Corporation President Carlo Miguel;

5. Defendant further maintains that on the same day, defendant handed to Mr.
Raul Roxas the forty-five thousand (P 45,000.00) Philippine peso, together with
the ten post dated checks all in the name of Mr. Raul Roxas;

6. Defendant claims that he has no knowledge that Mr. Raul Roxas resigned Last
20 June 2014 and went to Canada;

7. Therefore, defendant herein contends that the Notarized Lease Contract which
is pre-signed by ABC Corporation President is valid and that the defendant is
legally occupying the premises;

8. Defendant has no cause of action against the Plaintiff herein.

P R A Y E R
WHEREFORE, in view of the foregoing, Defendant respectfully prays before
this Honoroble Court that the present Complaint be DISMISSED for lack of merit.
Quezon City, Metro Manila.
2 September 2014.

ATTY. APRIL ROSE LERIT
Counsel for theDefendant
458, Fr. Hofstee St., Tala
Caloocan City
Roll of Attorney No. 10008
PTR. NO 1110, Quezon City
IBP NO. 0125, Quezon City
MCLE No. IV-1234




3
Annex 3 (Copy of Notarized Lease Contract dated 08 July 2014)


V E R I F I C A T I O N
I, Juan W. Dela Cruz, after having sworn in accordance with law, hereby states:
1. I am the Defendant in the above-captioned case;
2. Paragraphs 1, 2 and 3 of the complaint is specifically denied under oath;
3. Annex 1, 2 and 3 hereto attached in the Answer is specifically under oath