REPUBLIC OF THE PHILIPPINES

METROPOLITAN TRIAL COURT

City of Taguig
Branch 1

GYKKA TESORO,
Plaintiff,
CIVIL CASE No. 98765
-versus- FOR: Unlawful Detainer

DIORICO IBANEZ,
Defendant.

x-----------------------------------x

ANSWER WITH COUNTER-CLAIM

Respondent, through the undersigned counsel, most respectfully file his Answer in response to the Complaint
of the Plaintiff and interpose as well as his counterclaim against the latter, to wit:

ADMISSIONS AND DENIALS

1. Paragraphs 1 and 2 are admitted;

2. Paragraphs is denied because the plaintiff is not the absolute owner of the house and respondent is without any
knowledge or information sufficient to form a reasonable belief thereof;
3. But insofar as the allegation in the paragraph 3 is concerned, that there was a contract of lease with the plaintiff, the
same is denied because he was not the owner of the property and had no authority to execute such contract in behalf
of the owner.
4. The allegation in paragraph 4 is denied as the same is an erroneous conclusion made by Plaintiffs;
5. The allegation in paragraph 5 is denied as the same is an erroneous conclusion made by Plaintiffs;
6. The allegation in paragraph 6 insofar as the letter of demand sent is concerned is admitted.
7. The allegation in paragraph 7 is denied as the same is an erroneous conclusion made by Plaintiffs;

8. The allegations in paragraph 8 is denied the truth being that stated in the affirmative and special defenses hereunder;

9. The allegations in paragraph 8 is denied the truth being that stated in the affirmative and special defenses hereunder;

Affirmative and Special Defenses

10. The Complaint filed by Plaintiffs is nothing but a malicious lawsuit calculated to harass the Defendants and should
therefore be dismissed;
11. Neither special power of attorney nor authority to enter into any lease contract involving the said house is produced
by the plaintiff;
12. After a painstaking review of the Complaint, it is apparent from the allegations therein that the plaintiff seek to harass
and extract money from the respondent on the basis of unsupported claim of ownership;
13. My sister is the real owner of the house.
14. Due to the malicious filing of this instant suit, Defendant have hired the services of the undersigned counsel for an
agreed amount of Philippine Pesos: Five Hundred Thousand (PHP 500,000.00) and have suffered sleepless nights
and besmirched reputation which when quantified in monetary terms is in the amount of Philippine Pesos: Two
Hundred Thousand (PHP 200,000.00)

PRAYER

WHEREFORE, in view of the foregoing, Defendants most respectfully pray for the dismissal of the complaint and the
award of counterclaim to them. Other reliefs are likewise prayed for.

City of TAGUIG, May 20, 2019.

MODEL LAW OFFICE

Counsel for the Plaintiff
Unit 123, Victoria Tower I
Taft Avenue, Manila

By:
Model G. Tesoro
Roll of Attorney No. 98765
IBP No. 12345/2-5-12/Manila
PTR No. 87654/12-22-11/Manila

VERIFICATION/CERTIFICATION OF FORUM SHOPPING

Republic of the Philippines )

City of TAGUIG ) S.S.

I, Gykka G. Tesoro, of legal age, Filipino citizen, single and resident of313 Taguig City Apartelle, Western
Bicutan, Taguig City, after having been duly sworn to in accordance with law do hereby depose and say that:
1. I am the plaintiff in the above-entitled case;
2. I caused the preparation of the foregoing complaint and have read the allegations contained therein;
3. The allegations in the said complaint are true and correct of my own knowledge and authentic records;
4. I hereby certify that I have not commenced any other action or proceeding involving the same issues in any court,
tribunal or quasi-judicial agency and, to the best of my knowledge, no such other action or claim is pending therein;
5. If I should learn thereafter that a similar action or proceeding has been filed or is pending, I hereby undertake to report
that fact within five (5) days therefrom to the court or agency where the original pleading and sworn certification
contemplated herein have been filed;
IN WITNESS WHEREOF, I have hereunto affixed my signature this May 20, in the City of Manila.

GYKKA G. TESORO

SUBSCRIBED AND SWORN to before me this _______ day of May, 2019, in the City of Manila, affiant exhibiting
to me his Driver’s License No. 12345 issued by the Land Transportation Office on April 8, 2015 at the City of Manila.

MODEL G. TESORO
Notary Public
My Commission Expires Dec. 31, 2021
Roll of Attorney No. 34567
IBP No. 12345/2-5-12/Manila
PTR No. 87654/12-22-11/Manila

Doc. No. ________

Page No. _______
Book No. _______
Series of 2012