Republic of the Philippines REGIONAL TRIAL COURT of MISAMIS ORIENTAL 10th Judicial Region Branch 21 Cagayan de Oro City

INDIAN LENDER -VersusCHESTER C. CASTAOS, Defendant. x- - - - - - - - - - - - - - - - - - - - - - - - - - - - - / ANSWER

NOW COMES the defendant in the above-entitled case, and to this Honorable Court most respectfully alleges:
1.

Plaintiff,

Civil Case No. 14-14344 For: Collection of Sum of Money, Damages and Attorneys Fees

Defendant admits the averment in paragraph 1 Defendant specifically denies the allegation in paragraph 4 and 5 of the complaint, the truth being that. ( State here the fact being claimed by the defendant as the true state of facts or the truth being those stated in the special and affirmative defenses herein set forth) Defendant has no knowledge or information to form a belief as to the truth of the averment in paragraphs 8,9,10,11 and 12 of the complaint;

2.

3.

By way of special and affirmative defenses, defendant avers:

1. 2.

That the obligation has been paid; That the defendant had purchases said land from plaintiff and paid said promissory notes;

3.

That the cause of action has prescribed.

By way of counterclaim, defendant alleges:

1.

That by virtue of this unwarranted and malicious act initiated by the plaintiff, defendant was forced to engage counsel in the sum of P10,000.00.

WHEREFORE, it is respectfully prayed that the complaint be dismissed and defendant be awarded the amount of P5,000.00

Other equitable reliefs are likewise prayed for.

Manila, Philippines, May 27, 2000.

ERNESTO FLORES Attorney for the Defendant

_______________________ Address

P.T.R. Issue______ Place of Issue_____

No.______ Date & Place of IBP O.R. No._____ Date &

(Under oath if document is denied.)

(Copy furnished with Proof of Service and Explanation)