REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

METROPOLITAN TRIAL COURT
MANILA, BRANCH 1

Michael Corleone, et al., plaintiff

Civil Case No. 00003
Accompanied by his Attorney in fact,
for:Unlawful Detainer
Atty. Jon Carl G. Malang
-versusBruno Tattaglia and Maria Tattaglia, defendants
x---------------------------------------------x

ANSWER
COMES NOW, the plaintiff together with the undersigned
counsel to this most honorable court, MOST RESPECTFULLY
STATES THAT;
1. That defendant admits the allegations stated in 1 ,2
and 5 of the complaint;
2. That in paragraph 5, the defendants admits that on
January 2006, a Deed of Absolute Sale for P2.5m was
executed for the house and lot owned by the heirs of
Don Vito and were allowed to take over but the title
shall be transferred only upon full payment.
3. That in paragraph 6 and 7, the defendants admits a
remaining balance of P338,000.00 but denies the
existence of demand letter issued on August 2, 2010.
4. The defendants allege that the contract between the
parties is not communicative of the period or term in
which the full payment for the sale will become due.

5. That in the absence of term of period, the complainant

has no right to demand for the unpaid balance until the
period has been fix. Thus the possession of place by
the defendant is lawful.
6. They admit the contents of paragraph 10 which states
that conciliation took place at the barangay on
December 15, 2013

PRAYER
WHEREFORE, premises considered, it is most respectfully prayed of
this Honorable Court that judgment be rendered in favor of the
plaintiff and that after judgment;
a) That the complaint against the defendant should be dismissed
with prejudice;
b) That the complainants improper prayer for attorneys fee and
monthly rentals should be denied;
c) That defendants be entitled for cost of suit incurred herein;
d) For such other, further relief as the court may deem just and
proper.
Such other reliefs and remedies under the premises are
likewise prayed for.
City of Manila, Philippines, this 28th day of February 2014.

Atty. Jon Carl G. Malang

Counsel for the Plaintiff
PTR No. 25487962:1-03-05:B.C.
IBP No, 1234567:1-03-05:B.C.
Roll No. 12345:5-10-07: Manila
123 Antipolo St.,
Sampaloc, Manila

VERIFICATION AND CERTIFICATION

I, Michael Corleone, of Legal age, single, Filipino Citizen and a

resident of 123 Sardonyx St., Tondo, Manila, after being sworn
according to law, hereby depose and state that;
1.
2.

I am the Complainant in this proceeding.

I have read and understood the filed complaint and
allegations therein.

Michael Corleone
Complainant
In witness thereof, I, Atty. Jon Carl G. Malang, counsel of the
plaintiff, have hereunto set my hand this 28 th of February at City of
Manila.
Atty. Jon Carl G. Malang
Counsel for the Plaintiff
PTR No. 25487962:1-03-05:B.C
IBP No, 1234567:1-03-05:B.C.
Roll No. 12345:5-10-07: Manila
789 Antipolo Street,
Sampaloc, Manila