Republic of the Philippines

7TH JUDICIAL REGION

Regional Trial Court
Branch _____
Cebu City

MILA C. PEREZ, Civil Case No. _____________

Plaintiff FOR: COLLECTION FOR A SUM
OF MONEY WITH DAMAGES
- versus -

JAO D. CRIS,
Defendant
x -----------------------x

REPLY
PLAINTIFF, thru the undersigned Counsel, unto this Honorable
Court, most respectfully submits this Reply to Defendant’s Answer with
Counterclaim, thus avers that:
1. Defendant, in paragraph 4 of his Answer with Counterclaim, alleged
that- “The Complaint filed by plaintiff is nothing but a malicious lawsuit
calculated to harass the Defendant..xxx”.
It is noteworthy to point out that his act of borrowing money
from the Plaintiff was evidenced by a promissory note duly signed by
him personally. Thus, defendant’s assertion that the Complaint filed
by the Plaintiff is nothing but a malicious lawsuit to harass him has no
basis;
2. Defendant, in paragraph 5 of his Answer with Counterclaim, alleged
that- “On February 25, 2018, the Defendant and the Plaintiff have
never seen each other because the former was having a vacation in
Singapore..xxx”
The truth is that Defendant never left the country because from
February 20-27, 2018, both the Defendant and Plaintiff attended a 7
day symposium entitled “MATERIALS MANAGEMENT AND
INVENTORY CONTROL - FOR THE MANUFACTURING AND
SERVICE INDUSTRY” held at Golden Peak Hotel. A copy of
 registration sheet indicating our name and attendance in the said
symposium is hereto attached as Annex “A” and copies of
photographs showing our presence with our friends in the said
symposium are hereto attached as Annexes “B” and “B-1”;
3. Defendant, in paragraph 7 of her Answer with Counter claim alleged
that – “Defendant did not sign the alleged promissory note and that
Defendant’s signature is forged.”
The truth is that it is highly incredible that Defendant did not
sign the promissory note because at the time the promissory note
was made and signed by the Defendant, we were at the presence of
our common friend Atty. John L. Martin. A copy of Atty Martin’s
affidavit attesting to the fact that the promissory note was made at his
presence and that the signature was not forged is hereto attached as
Annex “C”;
4. Defendant’s claim for moral damages is baseless as plaintiff only
sought judicial intervention because Plaintiff continues to refuse and
ignore Plaintiff’s repeated demands to pay his obligation.

5. Defendant-debtor has, as of this date, still has not paid herein Plaintiff
a single centavo and defaulted in the payment of the principal mount
of One Million Pesos (P1,000,000.00) with an interest of (5%) percent
per month causing the plaintiff severe damage and prejudice and loss
of her hard-earned money;

WHEREFORE, premises considered, it is hereby respectfully

prayed that the foregoing Reply to Defendant’s Answer with
Counterclaim be given due credence and consideration and the reliefs
prayed for in the Complaint be granted.
Finally, Plaintiff respectfully prays for such and other reliefs as may
be deemed just and equitable under the premises.
November 2, 2015, Caloocan City Philippines.

Counsel for the Plaintiff