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REPUBLIC OF THE PHILIPPINES

METROPOLITAN TRIAL COURT


NATIONAL CAPITAL JUDICIAL REGION
Mandaluyong City, Branch 60

JASMIN A. CRUZ,
Plaintiff.

-versus- CIVIL CASE NO. 12-9810


For: Unlawful Detainer
JOTHAM B. FUNCLARA,
Defendant.

ANSWER TO COUNTERCLAIM WITH MOTION TO SET-PRETRIAL

PLAINTIFF, by undersigned counsel unto this Honorable Court most respectfully


manifest that on June 20, 2018, he received a copy of the ANSWER WITH COMPULSARY
COUNTERCLAIMS of Defendant in the above-entitled case and, by way of an ANSWER
to new matters alleged, hereby state THAT:

I.

1. The allegations in Paragraphs 2 and 3 of the Answer with Compulsory


Counterclaim are admitted;

2. Paragraph 4 is specifically denied for lack of knowledge sufficient to form


as belief as to the truth or falsity thereof;

3. Allegation in Paragraph 5 is specifically denied, there being no authority


given to Plaintiff’s sister Ms. Minda Cruz to sell the leased property in behalf of the
plaintiff. The Deed of Sale, if not forged has therefore, no legal effect whatsoever;

4. Paragraphs 6 and 7 are specifically denied, the truth being that the present
action is a well-founded in fact and in law, filed in good faith to protect and vindicate the
rights of the Plaintiff violated by the Defendant; therefore, there is no basis whatsoever
for the Defendant to recover any damages, attorney’s fees nor expenses of litigation from
the Plaintiff.

II.

The issues are joined. The case is ripe for pre-trial.

1
PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of this Honorable


Court that the case be set for pre-trial.

Mandaluyong City, 22 June 2018.

Atty. SUNSHINE S. RED


Counsel for the Plaintiff
Worldwide Corporate Center Edsa Shaw Blvd., Highway Hills, Mandaluyong City
Roll No. 87541 IBP No. 463091 dated 06-06-12
MCLE Compliance No. 15-00054321