Professional Documents
Culture Documents
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ADMISSIONS AND DENIALS
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Truck without his knowledge and permission. It was not
taken in furtherance of his trucking business, but for their
personal leisure;
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Under the Civil Code, the following provisions govern the
prescriptive period within which a party may file an
action.
Art. 1150. The time for prescription for all kinds of actions, when
there is no special provision which ordains otherwise, shall be
counted from the day they may be brought. (1969)
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Benjamin Bigat failed to exercise extraordinary diligence at
the time the incident occurred.
xxx
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The responsibility treated of in this article shall cease
when the persons herein mentioned prove that they
observed all the diligence of a good father of a family to
prevent damage.
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given daily operational briefings and that the
company handbook is duly observed;
COUNTERCLAIMS
TIMELINESS
PRAYER
2. DISMISS the complaint for utter lack of merit and for being
baseless;
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A. ACTUAL DAMAGES in the amount of Two Hundred
Fifteen Thousand Pesos (P215,000.00);
4. GRANT such other relief consistent with law and equity, and
for costs.
RESPECTFULLY SUBMITTED.
By:
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Copy furnished:
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