REPUBLIC OF THE PHILIPPINES

SIXTH JUDICIAL REGION

MUNICIPAL TRIAL COURT IN CITIES
Iloilo City, Branch __
MAR BINAY,
Plaintif
-versusCivil case no. ____
For: Unlawful Detainer

JEJOMAR ROXAS,
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 1 and 2 only

insofar as his personal circumstances are concerned;

2.

That he ADMITS that the plaintiff is the lawful owner of a land over
which an apartment had been constructed, located at 23 Jaime Street, Jaro, Iloilo
City as cited in paragraph 3.

3.

That he ADMITS his obligation of paying the monthly rental

dues starting March 1, 2015 cited in paragraph 4
of the
complaint,

4.

That he DENIES the rest of the allegations cited in paragraph

5 as said defendant argue that he faithfully paid the monthly dues
on time and has copies of the receipts received by the secretary
of the plaintif with regard to his payment;

5.

That defendant has all the records of payments he made to

plaintif and has never received any demand or notices from him,
so that he also does not have information sufficient to form a
belief as the truth of the allegations in paragraph 6 and 7 of the
complaint and, therefore, DENY them.
WHEREFORE, the defendant respectfully prays that the
complaint be dismissed with costs against the plaintif.
Other relief and remedies as may be deemed just and
equitable under the premises are likewise prayed for.

City of Iloilo, January 19, 2016.

ATTY. ZENY MARIE MOLOMOLO

Notarial Commission Reg. No. 101
Valid until December 31, 2016
PTR No. 3213439, Iloilo City, January 5, 2015
IBP No. 756844, Iloilo City, January 3, 2015
Roll of Attorneys No. 86741, TIN: 639-432-096
MCLE Compliance No. IV-008798

REPUBLIC OF THE PHILIPPINES)

CITY OF ILOILO. . . . . . . . . . . . . . . )S.S.
X----------------------------------------------X

VERIFICATION AND CERTIFICATION

I, Ann Curtis, of legal age, single, Filipino and a resident of E. Lopez Street,
Jaro, Iloilo City, under oath depose and state that:
I am the Defendant in the above captioned case; I have caused the
preparation of the same; I have read the allegations contained therein; and I certify
that they are all true and correct to the best of my own knowledge.
I further certify under oath that I have not commenced any similar action
before the Supreme Court, Court of Appeals, or before any court, tribunal or
agency concerned; and should I learn of any similar cause of action filed before
any of the aforesaid bodies, I undertake to notify this Honorable Court within five
(5) days from notice.
In witness whereof, I have hereunto set my hand this 19th day of January,
2016 at Iloilo City, Philippines.

ANN CURTIS
Affiant

SUBSCRIBED AND SWORN to before me, this 18th day of January 2016 in the
City of Iloilo, Philippines, affiant appearing before me with his PRC ID No.
826859 issued on January 3, 2016 at Iloilo City.

ATTY. ZENY MARIE MOLOMOLO

Counsel for the Defendant
ZMM Law Office, Blk 8, Lt
8, Ledesco Village, La Paz,
Iloilo City
PTR No. 3213439, Iloilo City, January 5, 2015
IBP No. 756844, Iloilo City, January 3, 2015
Roll of Attorneys No. 86741, TIN: 639-432-096
Copy furnished:

ATTY. HOWELL G. SORONGON

Counsel for the Plintif
Sorongon Law Office, 123-A Lopez St.,
Jaro, Iloilo City
EXPLANATION
Copy of the foregoing ANSWER was served to plaintifs
counsel by registered mail due to time and distance constraints
and for lack of the undersigneds staf who can serve the same in
person.

ATTY. ZENY MARIE MOLOMOLO

Doc. No. _____;

Page No. _____;
Book No. I;
Series of 2016.