A N S W e R S

A N S W E R S
1. ANSWER DENYING GENUINENESS AND DUE EXECUTION OF INSTRUMENT

2. ANSWER OF DEBTOR TO PETITION FOR INSOLVENCY
3. ANSWER TO PETITION FOR CANCELLATION OF TITLE
4. ANSWER FOR PETITION FOR HABEAS CORPUS
5. ANSWER TO PETITION FOR LEGAL SEPARATION
6. ANSWER WITH NEGATIVE AND AFFIRMATIVE DEFENSES
7. ANSWER WITH PERMISSIVE COUNTERCLAIM
8. ANSWER WITH SPECIAL AND AFFIRMATIVE DEFENSES WITH
COUNTERCLAIM
9. ANSWER WITH SPECIFIC DENIAL UNDER OATH
10. ANSWER WITH INTERVENTION

1. ANSWER DENYING GENUINENESS AND DUE EXECUTION OF AN
INSTRUMENT
REPUBLIC OF THE PHILIPPINES
REGIONAL TRIAL COURT
FIRST JUDICIAL REGION
Branch 60
Baguio City
________

MICKEY S. INAKANU
Plaintiff, CIVIL CASE NO. _______
For: Annulment / Cancellation
of REM with Prayer for
- versus - Preliminary Injunction
with Issuance of TRO

DONDY N. AMETEN
Defendant.
x---------------------------x

ANSWER

NOW COMES the defendant, by the undersigned counsel, and in answer
to plaintiffs complaint, in the above-entitled case and to this Honorable Court
most respectfully alleges:
1. That defendant specifically denies under oath the genuineness and due
execution of the alleged promissory note (Annex B) attached to said
complaint;

2. That said promissory note was executed through fraud, threats, and
intimidation, and therefore null and void.

PRAYER
WHEREFORE, it is respectfully prayed that the complaint be dismissed,
with costs against the plaintiff.
Other relief's, just and equitable under the premises are likewise prayed for.
RESPECTFULLY SUBMITTED this 15
th
day of February 2014, Baguio
City, Philippines.

CINDY P. ENDENG
Counsel for the Defendant

Copy furnished by registered mail with registry return card:

(EXPLANATION)

2. ANSWER OF DEBTOR PETITION FOR INSOLVENCY

Republic of the Philippines
MUNICIPAL TRIAL COURT
Bontoc, Mountain Province

JOMAR MERAIZ,
Plaintiff Civil Case no. : 354673

- versus - For: Insolvency

KATYA JUAN,
Defendant
x -------------------------- x

A N S W E R

COMES NOW the defendant, the debtor mentioned in the above-entitled
insolvency proceedings, and in ANSWER to the petition to have him adjudged
insolvent alleges:

That she denies that she has committed any of the acts of insolvency set forth
in said petition, or that she is insolvent.

WHEREFORE, the undersigned prays that these proceedings be dismissed,
with costs, expenses, damages, and counsel fees as may be fixed and allowed by this
Honorable Court.

Baguio City, Philippines, February 26, 2014.

MARIA CORAZON VALENTIN-CABADING
Counsel for the Defendant

VERIFICATION

JURAT

PROOF OF SERVICE

EXPLANATION (if by mail)

3. ANSWER OF PETITION FOR CANCELLATION OF TITLE


JOSEPH RODRIGUEZ,
Plaintiff CIVIL CASE NO. 375864

- versus - FOR: Cancellation of Title

JASON ESTRADA,
Defendant
x -------------------------- x

A N S W E R

RESPONDENT, by undersigned counsel and to this Honorable Court,
answering the petition for cancellation of title, respectfully alleges:

1) He admits the allegations in par. 1 of the petition regarding the personal
circumstances and addresses of the parties.

2) He admits the allegations in pars. 2 to 5 to the petition, subject to
qualifications and affirmative defenses herein alleges;

By way of SPECIAL AND AFFIRMATIVE DEFENSES, respondent
alleges:

1) That the parcel of land in question is a conjugal property of respondent and
his wife, Letty Estrada;

2) That the court in Civil Case NO. 7593 has not acquired jurisdiction over the
person of his wife because she was not a party litigant therein:

3) That the money judgment in Civil Case No 7593 arose from the personal
transaction of petitioner in connection with the accommodation surety he
executed to secure payment of the loan extended by respondent to the
corporation, ICORP, which loan did not benefit the conjugal property, and
accordingly said conjugal property is exempt from execution to satisfy said
personal judgment of respondent.

4) That the execution sale is invalid because there was no valid levy made by
the sheriff, as at the time the court in Civil Case No. 7593 has not acquired
jurisdiction over the person of respondents wife, who was not a party litigant
in said case.

5) The value of the land in question has market value far exceeding the
amount of money judgment rendered in favor of petitioner, as to unfairly
and unjustly enrich petitioner.

6.) As the Supreme Court ruled in Padilla, Jr. v. Phil. Producers Cooperative
Marketing Assn., G.R. No. 141256, July 15, 2005:

It is clear that PD 1529 provides the solution to respondents quandary.
The reasons behind the law make a lot of sense; it provides due process to a
registered landowner (in this case the petitioner) and prevents the fraudulent
or mistaken conveyance of land, the value of which may exceed the judgment
obligation. Petitioner contends that only his interest in the subject lots, and
not that of his wife who was not a party to the suit, should have been subjected
to execution, and he should have had the opportunity to prove as much.

WHEREFORE, respondent respectfully prays that the petition be dismissed
for lack of merit.


counsel for the defendant

VERIFICATION

JURAT

PROOF OF SERVICE


4. ANSWER TO PETITION FOR HABEAS CORPUS


In the Matter of the Petitionof
KRIS CORTEZ,
Plaintiff,
Special Proceeding Case no.
12345

For: HABEAS CORPUS

- versus

The Chief Of Police Of Bontoc
Defendant.
x -------------------------------- x

A NS W E R

The undersigned respondent in the above-entitled case hereby makes due
return of the writ of Habeas Corpus issued by this Court on February 23, 2014, and by
way of answer, most respectfully states:

1) That the herein respondent has Kris Cortez under restraint in the police
detention cell at the Bontoc Police Department headquarters, pending completion of
and transfer to the city jail now under reconstruction;

2) That the herein respondent caused the apprehension of the said Kris Cortez
on January 30, 2013, and the authority, the true, and the whole story and cause of the
said restraint of the said person are the following, to wit:

a) That said party, Kris Cortez, was apprehended and placed under
police custody on suspicion of having smuggled unlicensed firearm found abandoned
in an army bag at the corner of Teresa and Magallanes Streets, this city, reported by a
person to have been carried by said Kris Cortez;

b) That in the evening of January 30, 2014 while investigation of the
detainee was being conducted, the Warrant Section of the Bontoc Police Department
discovered among its files a warrant for the arrest of said Kris Cortez issued by the
Regional Trial Court of this city, Branch II, in Criminal Case No. 7593 entitled
People of the Philippines vs. Kris Cortez for the crime of Assault upon a person in
Authority;

c) That in the above-mentioned criminal case, the detainee has not
posted a bond for her provisional liberty up to the present time;

d) That said detainee has been detained temporarily in the police
detention cell of the Bontoc Police Department in view of the destruction through fire
of the Bontoc City Jail;

e) That a copy of the warrant of arrest issued against Kris Cortez is
Criminal Case No. 7593 entitled People of the Philippines vs. Kris Cortez
commanding her apprehension, is hereto attached as Annex A made an integral
part of this return and answer.

WHEREFORE, all the foregoing premises considered, it is respectfully
prayed that the petition for Habeas Corpus be dismissed, and that the said Kris
Cortez be ordered to remain in the custody of the Bontoc Police Department.


AURELIO BALTAZAR
Chief of Police, Bontoc
Respondent

VERIFICATION

JURAT

PROOF OF SERVICE


5. ANSWER TO PETITION FOR LEGAL SEPARATION

First Judicial Region
Branch 8
Baguio City

BERGAN NUNEZ,
Plaintiff, CIVIL CASE NO. 1234-R
For: LEGAL SEPARATION
versus
JANINE NUNEZ,
Defendant.
x------------------------------x
ANSWER

COMES NOW, the defendant, in answering petitioners petition for legal separation,
alleges that :

1. He admits the allegations in par. 1 of the petition regarding the personal
circumstances and addresses of the parties; and

2. He denies the allegations in the rest of the petition, the truth being that he
was forced to leave the conjugal home because petitioner committed acts
which are also ground for legal separation, such as sexual infidelity,
attempt on the life of respondent and abusive conduct against their two
children.

PRAYER

WHEREFORE, respondent prays that the petition be dismissed for lack of
merit.

Such other reliefs and remedies which may be just and equitable under the
circumstances are likewise prayed for.

This 15
th
day of February 2014 in the City of Baguio, Philippines.

(Counsel for the Defendant)
VERIFICATION

JURAT

PROOF OF SERVICE


6. ANSWER WITH NEGATIVE AND AFFIRMATIVE DEFENSES

Branch 8
Baguio City
PERLA BANANA,
For: Annulment / Cancellation of REM
versus with Prayer for Preliminary
Injunction with Issuance of TRO
SABEL CABRERA,
Defendant.
x------------------------------x

ANSWER

COMES NOW, the defendant, through the undersigned Counsel respectfully
states that:

1. Defendant admits that portion of par. 1 of the complaint regarding the
names, residences and status of the parties, but denies the rest thereof, for lack of
knowledge sufficient to form a belief as to the truth thereof.

2. Defendant denies under oath the execution and authentication of the
promissory note, Annex A of the complaint, the truth being that the same is a
forgery and that he did not execute nor sign the same.

3. Assuming, arguendo, that the promissory is genuine and duly executed; it
was executed by a person on behalf of defendant, without any authority from
defendant.

4. Assuming, further, that the agent who signed the promissory note on behalf
is duly authorized to do so, the amount of indebtedness therein stated represented
payment of gambling losses of defendant in favor of plaintiff.

5. Assuming, finally, that the indebtedness shown in the promissory note and
the promissory note is legitimate, plaintiff has been paid the amount thereof.

PRAYER

WHEREFORE, defendant respectfully prays that the complaint be dismissed
for lack of merit, with costs against plaintiff.

This 15
th
day of February 2014 in the City of Baguio, Philippines.

VERIFICATION

JURAT

Copy furnished (by personal delivery):

(Counsel for the Plaintiff)

7. Answer with Permissive Counterclaim

Branch 8
Baguio City
KEI MOLLY,
For: Annulment / Cancellation of REM
versus with Prayer for Preliminary
Injunction with Issuance of TRO
ANGELA MANZANO,
Defendant.
x---------------------------------x

ANSWER

COMES NOW, the defendant, through the undersigned Counsel and unto
this Honorable Court most respectfully states that:

1. The subject matter of the complaint is specific performance of contract, and
the permissive counterclaim has no relation to such subject matter of complaint, as
follows:

Plaintiff and defendant entered into a contract of sale of clothing
materials on or about February 19, 2013, whereby defendant would
deliver to plaintiff such materials worth Three Million Pesos (Php 3,
000, 000.00) and the plaintiff would in turn pay the same, upon such
delivery.

2. The defendant having delivered said clothing materials on February 19,
2013 to plaintiff, but the latter, notwithstanding repeated demands, both oral and
written, failed and refused to pay the same and still fails and continues to refuse to
pay the purchase thereof, in breach of his obligation.

PRAYER

WHEREFORE, defendant respectfully prays that the complaint be dismissed
for lack of merit.

Under his counterclaim, judgment be rendered ordering plaintiff to pay the
amount of Three Million Pesos (PhP 3, 000, 000.00), with legal interests therein
until the principal amount and interest are fully paid.


This 15
th
day of February in the City of Baguio, Philippines.


VERIFICATION and CERTIFICATION AGAINST FORUM SHOPPING

JURAT



8. ANSWER WITH SPECIAL AND AFFIRMATIVE DEFENSES WITH
COUNTERCLAIM

MUNICIPAL TRIAL COURT IN CITIES
Branch 1
Baguio City

RANDY SINGER, Civil Case No. _____
Plaintiff, For: Unlawful Detainer

versus

JOHN GRISHAM,
Defendant.
x------------------------------------------x

ANSWER

Defendant, by counsel and unto this Honorable Court, most respectfully avers
that:

1. Defendant has no personal knowledge as to the allegations in
paragraphs 1 and 3 of the Complaint;

2. Defendant admits the allegations in paragraph 2;

3. Defendant specifically admits the allegations in paragraph 4 that he
entered into a contract of lease with Plaintiff over an apartment
located at Sanitary Camp for a consideration of Php8,000.00 a
month as rental to be paid within the first ten (10) days of each
month starting January 6, 2011;

4. Defendant specifically admits that he failed to pay the agreed rental
but only from August, 2012 up to present, when Plaintiff has already
brought the matter before the Barangay Authorities and later to this
Honorable Court;

5. Defendant denies the allegations in paragraphs 6 and 7, the truth
being that Plaintiff instituted this action without making any

demands upon Defendant to vacate the leased premise and that the
demand letter was received not by the Defendant but by the
Defendants minor child;

6. Defendant admits the allegations in paragraph 8 that there was no
settlement reached because there was no sincere efforts by the
parties concerned to pursue amicable settlement;

7. Defendant denies the allegations in paragraph 9 for lack of personal
knowledge sufficient to form a belief as to the truthfulness
thereof;By way of Affirmative Defense, the complaint should be
dismissed on the ground that the case has not properly gone through
the required Barangay Conciliation and is still under consideration,
as properly shown by the minutes of the Office of the Punong
Barangay hereto attached as Annex A;

8. By way of Counterclaim, considering that the Plaintiff has in bad
faith and without any cause of action filed the instant case for which
the Defendant was constrained to answer the same, Defendant
should be awarded moral damages in the sum of Php 20,000.00 and
attorneys fees in the sum of Php 10,000.00.

PRAYER

WHEREFORE, premises considered, Defendant most respectfully prays unto
this Honorable Court that judgment be rendered in his favor:

1. DISMISSING the instant Complaint;

2. GRANTING his counterclaim;

3. GRANTING such other just and equitable reliefs as may be deemed
proper.

Baguio City, Philippines, April 5, 2013.


VERIFICATION and CERTIFICATION AGAINST FORUM SHOPPING

JURAT


9. ANSWER WITH SPECIFIC DENIAL UNDER OATH

MUNICIPAL TRIAL COURT IN CITIES

Branch 1
Baguio City

JAYSON UPTON, Civil Case No. _____
Plaintiff, For: Collection of Sum of Money

- versus -

MATT REDMAN,
Defendant.
x------------------------------------------x
ANSWER

Defendant, by counsel and unto this Honorable Court, most respectfully avers
that:

1. He admits the allegations in paragraphs 1 and 2 of the Complaint.

2. He denies the allegations in the rest of the Complaint, such that, he
specifically denies under oath the genuineness and due execution of the
alleged promissory note (Annex A), attached to said Complaint, the truth
being, that the same is a forgery and that he did not execute nor sign the
same.
PRAYER

WHEREFORE, premises considered, Defendant most respectfully prays that
judgment be rendered in his favor DISMISSING the instant Complaint.

Other just and equitable reliefs are likewise prayed for.


Counsel for Defendant

VERIFICATION (with SPECIFIC DENIAL UNDER OATH)

JURAT

PROOF OF SERVICE


10. ANSWER WITH INTERVENTION

Branch VI
Baguio City

DON MOEN, Civil Case No. _____
Plaintiff, For: Partition

versus

BROOK FRASER,
Defendant.
x------------------------------------------x
ANSWER-IN-INTERVENTION

Defendant, by way of answer to the complaint-in-intervention, by counsel,
most respectfully alleges that:

1. He is one of the co-owners of the property, subject matter of the
petition for partition.

2. He has sold his undivided share in the subject property to Plaintiff-
Intervenor.

3. He admits having sold his undivided share in the property in question
to DON MARIANO, as shown in the copy of the Deed of Sale, Annex A
of the complaint-in-intervention, but he avers in this connection that
the buyer, DON MARIANO has not fully paid the consideration.

4. By way of COUNTERCLAIM, Defendant alleges that:

a. Plaintiff-intervenor has not paid the full purchase price of the
property to Defendant, as he has an unpaid balance of
Php200,000.00, which he refused to pay and still continues to
refuse to pay, notwithstanding demands.

PRAYER

WHEREFORE, premises considered, Defendant most respectfully prays:

1. The complaint-in-intervention be dismissed for lack of merit;

2. Alternatively, Don Mariano be ordered to pay the balance of the purchase
price of Php200,000

3. Other just and equitable reliefs be granted.



PROOF OF SERVICE


A N S W e R S

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1. ANSWER DENYING GENUINENESS AND DUE EXECUTION OF INSTRUMENT

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