Republic of the Philippines

REGIONAL TRIAL COURT

Third Judicial Region
BRANCH _____
Cabanatuan City
oOo

PETER SICAT,
Plaintiff

- Versus - CASE NO. _______________

For: Collection of Sum
Of Money

ARNEL ROMERO
Defendant
x - - - - - - -- - - - - - - x

ANSWER

Comes now DEFENDANT, thru the undersigned counsel unto

this Honorable Court, by way of answer to the instant complaint most
respectfully avers that :

1.) Paragraphs 1 and 2 of the complaint are admitted insofar

as the personal circumstances of the parties are concerned;

2.) Paragraph 3 is admitted insofar as the circumstances that

he merely invited me to the bar and the total amount paid is
concerned ;

3.) Paragraphs 4 and 5 are vehemently opposed and

denied as the real facts and circumstances that transpired was, we
have no agreement that I will pay our bill, the truth is, he only invited
me to join him because he don’t want to go to the bar alone, and
because of our friendship, I did not refuse to go with him;

4.) That the reason why I issued the said check was because,
during that time, he was very importunate and forcing me to pay our
bill;

5.) That because my mind was also influenced with alcohol

during that night, I was forced to issue the said check;

6.) The allegation in paragraph 8, is vehemently opposed and

denied as the real facts and circumstances that transpired in the
instant case clearly show that it is the defendant who stand to suffer
loss and damages due to the said acts of the plaintiff.

COUNTER–CLAIM

7.) By way of counter-claim, herein defendant further aver;

8.) As a result of this baseless suit against herein defendant, he

incurred and suffered the following damages which must be
chargeable to herein plaintiff, to wit ;

a.) Actual damages in the amount of 20,000 pesos

b.) Moral damages in the amount of 10, 000 pesos
c.) Attorney’s fees in the amount of 20,000 pesos

PRAYER
WHEREFORE, premises considered it is respectfully
prayed to this Honorable Court in the spirit of truth, justice, and
righteousness, and fairness that the said complaint against herein
defendants be dismissed for lack of merit, and an order be issued
requiring the plaintiff to pay the following ;

a.) Actual damages in the amount of 20,000 pesos

b.) Moral damages in the amount of 10, 000 pesos
c.) Attorney’s fees in the amount of 20,000 pesos

Other reliefs just and equitable under the premises are likewise
prayed .

Cabanatuan City, September 30, 2017

ATTY. JHOANA P. FRANCISCO

Counsel for the Plaintiff
# 456, ORTIZ Apt./Bldg., Maharlika Hi-way
Brgy. Dicarma, Cabanatuan City
PTR.No. CBN-0740789-1-04-2016, Cab. City
IBP No. 0989787-1-04-2016
Roll No. 45770, MCLE IV-0002636

Copy furnished:
ATTY. JHOANA P. FRANCISCO
Counsel for the plaintiff
# 456, ORTIZ Apt./Bldg., Maharlika Hi-way
Brgy. Dicarma, Cabanatuan City

EXPLANATION

Personal service of copy to the other party/parties being

impractical for lack of man power hence, resorted to service of copy
via registered mail.

ATTY. JHOANA P. FRANCISCO

 VERIFICATION and CERTIFICATION
I, ARNEL ROMERO, of legal age, Filipino, after being duly
sworn to in accordance with law, hereby depose and say:

1. That, I am the DEFENDANT in this case;

2. That I have caused the preparation and filing of the

foregoing ANSWER with COUNTER-CLAIM;

3. That I have read and understood the contents therein;

4. That all the allegations therein are true and correct

according to my own knowledge and based on authentic
records.
AND I HEREBY CERTIFY THAT;

5. I have not commenced any other action or proceeding

involving the same issue in the Supreme Court, Court of
Appeals, or Division thereof, or any other tribunal or agency;

6. To the best of my knowledge, no such action or proceeding

is pending in the Supreme Court, Court of Appeals, or
Division thereof, or tribunal or agency;

7. If there is such other action or proceeding, I must state the

status of the same;

8. If I should thereafter learn that a similar action or proceeding

has been filed or is pending before the Supreme Court,
Court of Appeals, or any tribunal or agency, I undertake to
promptly notify the aforesaid court and other tribunal or
agency of that fact within five (5) days there-from.

IN WITNESS WHEREOF, I have hereunto set my hand this

_________________________, here at Cabanatuan City.

ARNEL ROMERO
Affiant
ID No: C05-13-25487
Issued by: Land Transportation Office

SUBSCRIBED AND SWORN to before me this

__________________________, here at Cabanatuan City