Republic of the Philippines

REGIONAL TRIAL COURT

7th Judicial Region
Branch 5
Cebu City

VISAYAN ELECTRIC CO., INC.

Plaintiff,
CIVIL CASE NO.
___________
-versus- For: DAMAGES
BASED ON
TORTS AND
DAMAGES
ROWELMA N. MARANAN
Defendant
x--------------------------------x

ANSWER

Comes now, Defendant Rowelma Maranan through

counsel and unto this Honorable Court, most
respectfully state:

1. Allegations in paragraph 1 and 2 of the Complaint is

admitted;

2. Allegations in paragraph 3 of the Complaint regarding

the Forty six thousand Five hundred forty three pesos
and twenty five centavos (P46.543.25) for the power
consumed for the period December 26, 2016 to January 25,
2017 is admitted;

3. Allegations in paragraph 4 of the Complaint for failure

to pay is denied for lack of knowledge and information to
form a belief thereof and by way of special and affirmative
defenses;

4. Allegations in paragraph 5 of the Complaint is denied

for lack of knowledge and information to form a belief
thereof and by way of special and affirmative defenses;

AFFIRMATIVE DEFENSES

5. That Defendant did not personally receive the demand

letter and it was her house servant who abscond without

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notice who received the 2 demand letters sent;

6. That up to this time, the defendant was having a

vacation outside of the country until March 5;

7. That said claim of the complaint readily shows that

this case is not within the exclusive original jurisdiction of
the Regional Trial Court of Cebu City and should be
considered as a mere scrap of paper by this court;

8. That the Plaintiff for not complying with the formalities

required for failure to sign the said complaint should be
denied and should be considered as a mere scrap of paper;

COUNTERCLAIM

Answering Defendant replead and incorporate the

allegations in the Answer and the Affirmative Defenses and
further state:

9. That filing of the baseless and malicious complaint

caused sleepless nights, mental anxiety and wounded
feelings to the Defendant hence, the plaintiff should be
condemned to pay moral damages to herein Defendants in
the sum of not less than One Hundred Thousand Pesos (P
100,000.00);

10. That to protect and enforce the rights and interest of

the answering Defendants he was compelled to engaged the
services of a lawyer whom he promised to pay Fifty
Thousand Pesos (P 50,000.00) and which should be
reimbursed by the plaintiff.

PRAYER

WHEREFORE, premises considered it is respectfully

prayed to this Honorable Court that the Complaint be
dismissed for lack of merit in the interest of justice, fairness
and equity and prays for lack of exclusive jurisdiction of this
Honorable Court and should be considered as a mere scrap
of paper.

Other reliefs and remedies are also prayed.

Cebu City, Philippines.

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 March 5, 2016.

KIER CHRISTIAN
RHENIER INVENTO
Counsel for Rowelma N. Maranan
Mabini Parian Cebu City
IBP NO. 16499-Dec. 3, 2014
Cebu, City
PTR NO. 559718- Jan. 6,
2015
Cebu, City
Roll of Attorney No. 31311
MCLE COM. CERT. NO. IV-
0023350
Issued on Feb. 21, 2013

EXPLANATION

Copy of the ANSWER is served to the defendants

counsel at his given address and done so because of
distance of offices between counsels.

Kier Christian Rhenier Invento

VERIFICATION AND CERTIFICATION OF NON-FORUM

SHOPPING

I, Rowelma Maranan of legal age, after having been duly

sworn in accordance with law, depose and state that;

1. I am a Defendant in the above-stated case;

2. I caused the preparation of the foregoing ANSWER;

3. I have read the contents thereof and the facts stated

therein are true and correct of my personal knowledge
and/or on the basis of copies of documents and records in
my possession;

4. I have not commenced any other action or proceeding

involving the same issues in the Supreme Court, the Court of
Appeals, or any other tribunal or agency;

5. To the best of my knowledge and belief, no such action

or proceeding is pending in the Supreme Court, the Court of
Appeals, or any other tribunal or agency;

6. If I should thereafter learn that a similar action or

proceeding has been filed or is pending before the Supreme

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Court, the Court of Appeals, or any other tribunal or agency,
I undertake to report that fact within five (5) days therefrom
to this Honorable Court.

Rowelma Maranan
Affiant

SUBSCRIBED AND SWORN to before me this 7 day of

March 2016 at Cebu City affiant exhibiting to me his
Community Tax Certificate No.545754578 issued on
____7th_March__ 2017 at __Cebu__ City.

Doc. No. ;
Page No. ;
Book No. ;
Series of 2016.

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