REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

7th Judicial Region
Branch 19, Cebu City
RONALD,
Plaintiff,
- versus -

CIVIL CASE NO. 43210

FOR: Collection of Sum of
Money and Damages

ARNOLD,
Defendant.
x-------------------------------------------------------x

ANSWER
COMES NOW the Defendant, ARNOLD, thru the
undersigned counsel, to this Honorable Court, respectfully
admits the following:
1. That the defendant lives in Brgy. Tisa, Cebu City, Cebu.
2. That the defendant and the plaintiff are childhood best
friends.
3. That the defendant and the plaintiff are both married.
4. That the defendant borrowed and amount of P500. 000.
00 from the plaintiff which is payable for one year.
However, the defendant to this Honorable
respectfully denies the following allegations:

Court

1. That he never executed a promissory note which was

allegedly advised by a lawyer friend and hereby
questions the genuineness of the promissory note
attached as Annex A in the plaintiffs complaint.
2. That the plaintiff never approached the defendant to
demand for payment.
3. That the defendant did not received any demand letter
from the plaintiff attached as Annex B, C and D.
WHEREFORE,
it is respectfully prayed that the plaintiffs
complaint be dismissed with costs against the plaintiff. The
defendant further prays for the following relief:
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1. To order the plaintiff to pay the expenses of litigation on

the amount of not less than 250, 000.00 with attorneys
fee.
2. To order the plaintiff to pay for moral damages in favor
of the defendant for the latter suffered sleepless nights
and anxiety due to the false and baseless accusations
of the plaintiff.
Defendant likewise prays for such other and further
relief or reliefs as this Honorable Court may deem just and
equitable in the premises.

ATTY. REALITY MAE S. TABERNERO

Counsel for the Defendant
2/F Escasinas Building
123 N. Bacalso St. Mambaling, Cebu City
IBP No. 11122, 01/02/15, Cebu City
PTR No. 12345678, 01/017/15, Cebu City
Attorneys Roll No. 762347
MCLE Compliance No. 112457

VERIFICATION AND CERTIFICATION OF

NON-FORUM SHOPPING
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I, Arnold, of legal age, Filipino citizen, and resident of

Barangay Tisa, Cebu City, Cebu, under oath, do hereby
depose states that:
1. I am the defendant in the said case;
2. I have caused the preparation of this answer pleading
and I attest to the veracity of all the allegations stated
herein;
3. I have read and understood all the allegations herein
and that I attest to the authenticity and veracity of all
the documents attached herein as based on existing
and authentic records;
4. I further certify that I have not commenced or filed any
claim involving the same issues herein with any other
Court. Tribunal or Quasi-Judicial Agency or I am not
aware of any such other case or claim pending before
any other court, tribunal or quasi-judicial agency; and
5. Should I thereafter learn of the filing or pendency of
such similar action or claim, I will inform this Honorable
Court of such fact within five (5) days from knowledge
thereof.
IN WITNESS WHEREOF, I have hereunto affixed my
hands this 7th day of March, 2015 at Cebu City, Philippines.
SUBSCRIBED and SWORN TO before me this 7th day
March, 2015 at Cebu City, Philippines, affiant exhibiting to
me his CTC # 4648154 issued on 20 th day of February at
Cebu City, Philippines.

ARNOLD
Affiant
CTC # 4648154 Cebu City
February 20, 2015
Doc. No. 0002
Page No. 0027
Book No. 004
Series of 2015
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