REPUBLIC OF THE PHILIPPINES

MUNICIPAL CIRCUIT TRIAL COURT

Surigao Del Norte

ROSITA B. ESPENIDO,
Plaintiff,

-versus- CIVIL CASE NO. 1 for Unlawful

Detainer

JUAN DE LA CRUZ,
Defendant.
x--------------------------------------------x

ANSWER
COMES NOW, the defendant, through the undersigned counsel and unto
this Honorable Court, most respectfully avers:

1. That he ADMITS the contents of paragraph 2 only insofar as the

allowance for the use of the cocoland but not as to the number of years
alleged;
2. That he ADMITS the verbal agreement made stated in paragraph 4;
3. That defendant is without knowledge or information sufficient to form
a belief as to the veracity of the averments in paragraph 5 of the
complaint;
4. That defendant ADMITS his obligation to take care of the property
with utmost diligence as cited in paragraph 6.
5. The defendant DENIES the averments made by the plaintiff in
Paragraph 7. The plaintiff made continuous visit in the subject
 property. The defendant even remitted to the plaintiff all her share in
the quarterly coconut harvests.
6. The defendant ADMITS paragraph 8 that the there was a confrontation
made between him and the plaintiff but it was not about his use of the
property but the increase of her share in harvested coconuts.
7. The defendant DENIES paragraph 8 in that the defendant didn’t
receive any demand to vacate letter from the plaintiff.
8. That defendant is without knowledge or information sufficient to form
a belief as to the veracity of the averments in paragraph 10 of the
complaint;

WHEREFORE, the defendant respectfully prays that the complaint be

dismissed with costs against the plaintiff.

Other relief and remedies as may be deemed just and equitable under
the premises are likewise prayed for.

Del Carmen Surigao Del Norte, June 21, 2018.

ELPA LAW OFFICE
Counsel for the Defendant
Suite 258 The Tower
Malate, Manila

By:

ATTY. ERIC CARLO B. ELPA

Roll No. 98765
IBP No, 12345/1-3-2017/Surigao
 PTR No. 34567/1-3-2017/Surigao

Copy furnished:
ATTY. MARIA NORMA ESTUBO
Counsel for the Plaintiff
Unit 1234 Surigao Tower
Surigao City, Surigao Del Norte

EXPLANATION

Copy of the foregoing ANSWER was served to plaintiff’s counsel by

registered mail due to time and distance constraints and for lack of the
undersigned’s staff who can serve the same in person.

ERIC CARLO B. ELPA

 DEMAND LETTER

I am writing this letter to demand from you the amount of Php

10,000 as my share of the coconut harvests on my property. Futher,
starting next month, I will be starting to collect 2000Php as payment for the
rent of my cocoland. Failure to comply with this demand shall result to
automatic termination of our oral agreement.

Thank you.

ROSITA ESPINIDO

Date:__________________