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Republic of the Philippines

NATIONAL CAPITAL JUDICIAL REGION


REGIONAL TRIAL COURT
Branch 5, Quezon City

ABC
Plaintiff ;
-versus-

CIVIL CASE NO.111222


FOR: Collection of sum of money

123
Defendant,

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

ANSWER
On February 24,2016 the Defendant received the copy of the Complaint and Annexes
where defendant is given the period of 15 days to file his own answer
Defendant 123,of Legal age and a Filipino residing at Postal Address BLK 1,Sampaguita
St. Sto.Nino ,Quezon City.Hereby unto this Honorable court and by way of answer to abovecaptioned-case ,respectfully states :

1. Paragraph 1 of complaint the is specifically denied for the lack of knowledge of


information sufficient to form a belief as to the truth of the allegations stated therein.
The allegation that last January 15,2015 , I ,123 being the Defendant did not enter in
any contract of loan with Plaintiff ABC. I have no specific knowledge of any contract
of Loan with the Plaintiff.
2. Paragraph 2 of the Complaint is specifically denied, the truth being that Plaintiff,
ABC , did not agreed to lend me the sum of PHP.700,000.00 .There is an insufficient
information to form a belief as to the truth of the allegations stated therein.
3. Paragraph 3 of the Complaint is specifically denied, the truth being The contract of
Loan attached therewith as Annex-A ,that the Defendant being I, did not agreed to pay
any sum of money on the agreed date of October 15,2015 and I did not agreed to
comply therewith.
PAGE 1

4. Paragraph 4 of the Complaint is specifically denied, the truth being that I did not
agreed to pay any amount borrowed from Plaintiff with interest of 10 % upon the
maturity of its debt.
5. Paragraph 5 of the Complaint is specifically denied, the truth being that I did not
agreed to Pay any amount with interest on the agreed resident of the Plaintiff ataed
therewith.
6. Paragraph 5 of the Complaint is specifically denied, the truth being I did not avoided
any messages to settle any obligations for the fact that I did not agreed to pay any
amount to the Plaintiff with its corresponding interest of 10%.
7. Paragraph 7,8,9 of the Complaint is specifically denied, the truth being that I did not
receive any Demand Letter addressed to me by the Plaintiff dated February 18,2016.

SPECIAL AND AFFIRMATIVE DEFENSES

9.The allegations in the preceeding paragraphs are hereby repleaded in so far as they are
relevant.
10.The complaint failed to state a sufficient cause of action on the part of the Defendant
123,as to the acts complained will not give rise for damages against the Defendant because there
was no obligation on the part of the Defendant to pay any sum of money with interest because
the Defendant did not agreed to enter in any contract of loan with the Plaintiff ABC.
11.That the Defendant 123 was not in the Philippines,and that he was in California to
attend his cousins wedding, around October 15,2015 when the contract of loan was made with
the Plaintiff,ABC.
12. That the Defendant 123 must have been mistaken as party in the contract of Loan
with the Plaintiff ABC.

PAGE 2

PRAYER
WHEREFORE, Premises considered ,defendant respectfully prays for the dismissal of
the complaint for lack of cause of action.
Defendant prays for such reliefs just and equitable under the premises

Sampaguita St. Sto.Nino ,Quezon City.,March 10,2016.

ATTY.JUAN DELA CRUZ

123

ATTY.FOR THE DEFENDANT

DEFENDANT

REPUBLIC OF THE PHILIPPINES )


QUEZON CITY ,PHILIPPINES

)S.S.

VERIFICATION
I,123, OF Legal age ,Filipino ,married and a resident of BLK 1,Sampaguita St.
Sto.Nino ,Quezon City Metro Manila after being duly sworn to in accordance with law,hereby
depose and state:
1.

I am the defendant in the above-captioned case.

2.

I have caused the preparation and filing of this answer.

3.
I have read and understand the contents of this Answer and all the allegations
contained therein are true and correct of my own knowledge and based on the authentic
document.
IN TRUTH THEREOF, we have hereunto affixed our signature this 10th of March 2016
at Quezon City,Metro Manila.

123

DEFENDANT
PAGE 3

ACKNOWLEDGEMENT

REPUBLIC OF THE PHILIPPINES )


QUEZON CITY ,PHILIPPINES

)S.S.

Before me, this 10th day of March,2016 , in the City of Quezon ,Metro Manila affiant
personally appeared known to me to be the persons who executed the foregoing instrument after
herein affiant has exhibited before me his valid ID with picture and signature to prove his
identity in conformity with the notarial Law.

IN WITNESS WHEREOF, I hereunto set my hand the day and year above written.

NOTARY PUBLIC

Doc.No. 4 ;

ATTY.JUAN DELA CRUZ


Address:151 Sampaloc St.Quezon City

Page No.2;

Roll No. 55143 /January 15,2010/ Quezon City

Book No.1 ;

PTR No. 2569426: /January 28,2010 Quezon City

Series of 2016.

IBP No.325694/February 20,2010


MCLE compliance No.

PAGE 4

III -5426121/April10,2010