REPUBLIC OF THE PHILIPPINES

METROPOLITAN TRIAL COURT

QUEZON CITY
Branch 123

ABC CORPORATION,
Plaintiff,
CIVIL CASE No. 000123
-versus- FOR: Unlawful Detainer
JUAN DELA CRUZ,
Defendant.
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A N S W E R

DEFENDANT, through the undersigned counsel, unto this Honorable Court,
respectfully avers:
Admissions/Denials
1. That he admits the allegations in paragraph 2 regarding his personal circumstances;
2. That he specifically denies paragraph 5 of the complaint which says that the Plaintiff
sent a letter to Defendant demanding him to vacate the area. No letter was received
from the Plaintiff;
3. That he also denies paragraph 3 which states that Defendant and his wife are
occupying the subject condominium for free because PLAINTIFF has paid forty
five thousand pesos (PhP45,000.00) as one month cash deposit and two months
advance cash deposit and also issued ten (10) post-dated checks covering the rentals
from March to December 2014;
Special and Affirmative Defenses
4. That the complaint does not state a cause of action and is a sham pleading;
4.1. That there was a lease contract between the Defendant and Plaintiff
which authorized the former to occupy the subject condominium unit;
4.2. That the said lease contract was signed by the Plaintiff and was also
notarized therefore should be given full faith and credit;

Counterclaim
5. Defendant additionally submits that he is entitled to relief arising from the filing of
this malicious and baseless suit, as follows:
5.1. Moral damages amounting to Thirty Thousand Pesos (PhP30,000.00)
because his name and reputation were besmirched by this malicious
baseless suit;
5.2. Despite paying all the necessary payment to rent the subject
condominium unit, one month deposit and two months advance and also
the post-dated checks, Plaintiff has instituted the instant malicious suit
which compelled the Defendant to engage the services of counsel, in
order to protect Defendants interest, for an agreed professional fee of
PhP300,000.00;
5.3. Defendant also incurred other litigation expenses in the sum of
PhP20,000.00. For all of said fees and litigation expenses, Plaintiff should
be adjudged liable to Defendant.


WHEREFORE, Defendant respectfully prays that judgment be rendered in his
favour by dismissing the Complaint and granting Defendants counterclaim by
awarding defendant: (a) Thirty Thousand Pesos (PhP30,000.00) as moral damages,
and (b) Three Hundred Thousand Pesos (PhP300,000.00) plus Twenty Thousand
Pesos (PhP20,000.00) for Attorneys fees.
Other just and equitable reliefs are prayed for.
Quezon City, 9 September 2014.

PRINCESS JOY B. FRANCISCO
Counsel for the Defendant
San Juan, Metro Manila
Roll of Attorneys No. 123456
IBP No. 101010
PTR No. 121218
MCLE No. 834398