[Court]

[Region]
[COURT]
[City], [Branch No.]
[NAME]__________,
Plaintiff,
Civil Case No. ___________
For: Collection of Sum of
Money

- versus [NAME]__________,
Defendant.
x ----------------------------------- x
ANSWER
(With COUNTERCLAIM)
DEFENDANT, by counsel, respectfully states that:
Admissions/Denials

1. He admits the contents of paragraph 1 only insofar as his personal

circumstances but specifically denies the contents insofar as plaintiffs personal
circumstances for the reason stated in the Affirmative Defenses below.
2. He admits the contents of paragraph 2 only where it states that a
Contract of Lease was entered into but specifically denies that the Contract
reflects the true intent of the parties as explained in the Affirmative Defenses
below.
3. He admits the contents of paragraph 3 only as to the fact that demand
to vacate was made but specifically denies its contents as to the truth of the
reasons for the letter for lack of knowledge sufficient to form a reasonable belief
as to its truth or falseness.
4. He specifically denies the contents of paragraphs 4 to 6 for the reasons
stated in the Affirmative Defenses below.
Affirmative Defenses
5. Defendant reiterates, repleads and incorporates by reference all the
foregoing insofar as they are material and additionally submit that the Complaint
should be dismissed because:
5.1. [STATE DEFENSES]
5.2 [STATE DEFENSES]
Counterclaim
6. Defendant reiterates, repleads and incorporates by reference all the
foregoing insofar as they are material and additionally submit that he is entitled
to relief arising from the filing of this malicious and baseless suit, as follows:
6.1. Moral Damages amounting to [AMOUNT IN PESOS IN
BOTH LETTERS AND FIGURES] because [STATE REASONS FPR THE
CLAIM] ____________________.

6.2.
Attorneys Fees amounting to [STATE AMOUNT IN
PESOS IN BOTH LETTERS AND FIGURES] _________________ because
he was compelled to secure services of counsel to vindicate his
legal rights.

WHEREFORE, Defendant respectfully prays that judgment be rendered in

his favor by
1. dismissing the Complaint, and
2. granting defendants counterclaim by awarding defendant
a. [AMOUNT IN PESOS] ____________ as Moral Damages, and
b. [AMOUNT IN PESOS] _____________________ as Attorneys Fees.
Other just and equitable reliefs are prayed for.

[CITY] ____________; [DATE] __________.

[SIGNATURE]
[NAME] _____________
Counsel for Plaintiff
[ADDRESS] ______________________

VERIFICATION & CERTIFICATION AGAINST FORUM SHOPPING

I, [NAME] ___________, of legal age, do hereby state that: I am the
defendant in the case filed by [PLAINTIFFS NAME] _______________ for [TYPE OF
CASE FILED] ____________; in response, I have caused the preparation of this
Answer with Counterclaim; I have read its contents and affirm that they are true
and correct to the best of my own personal knowledge; I specifically deny the
genuineness and due execution as well as the binding effect of the actionable
documents pleaded by plaintiiff; I hereby certify that there is no other case
commenced or pending before any court involving the same parties and the same
issue and that, should I learn of such a case, I shall notify the court within five (5)
days from my notice.
IN WITNESS WHEREOF, I have signed this instrument on [DATE] _________.
[SIGNATURE]
[NAME] ______________

SUBSCRIBED AND SWORN TO before me in the City of _______________ on

this day of [MONTH AND YEAR]_________________, affiant exhibiting before me his
Government Issued ID no. _______________ issued on [DATE}__________________ at
[PLACE OF ISSUANCE]_____________________.
[SIGNATURE]
[NAME]_______
Notary Public
Until [DATE]__________________
PTR No. [NUMBER] ____________

Issued at [PLACE]______________
On [DATE] ___________________
Doc. No.
Page No.
Book No.
Series of [YEAR] ___________.
Copy furnished through personal service:
[NAME OF COUNSEL] __________________
Counsel for the Plaintiff
[FIRM NAME] _______________
[ADDRESS] ________________
[USE THE FOLLOWING IF SERVICE IS NOT MADE PERSONALLY]
Copy furnished through registered mail:
[NAME OF COUNSEL] __________________
Counsel for the Plaintiff
[FIRM NAME] _______________
[ADDRESS] ________________
Registry Receipt No. ________
Post Office ________________
Date _____________________
EXPLANATION
The
foregoing
[DESIGNATION
OF
PLEADING,
MOTION,
ETC]
_______________and its attachment were served on [NAME OF COUNSEL]
________________ by registered mail instead of personal service as counsel for
petitioner [STATE REASON] ___________________.
[SIGNATURE]
[NAME] _________________

Republic of the Philippines

City of _______________

)
) s.s.
AFFIDAVIT

I, [NAME] ____________ , a messenger of [NAME OF COUNSEL FOR

DEFENDANT], with office address at [ADDRESS] __________________, after being
duly sworn, deposes and states:
That on [DATE] ______________________, I served a copy of the following
pleadings/papers by registered mail in accordance with Section 10, Rule 13 of the
Rules of Court:
Nature of Pleading/Paper
[STATE PLEADING/PAPER SENT]
________________________
in Case No. [CASE NUMBER] _________________ entitled [TITLE OF CASE]
____________________ by depositing a copy in the post office in a sealed envelope,

plainly addressed to [NAME OF PARTY/ATTORNEY] _______________ at

_______________ with postage fully paid, as evidenced by Registry Receipt No.
_____________________ attached and with instructions to the post master to return
the mail to sender after ten (10) days if undelivered.
TO THE TRUTH OF THE FOREGOING, I have signed this Affidavit on [DATE]
________________, in the City of [CITY] _____________, Philippines.
[SIGNATURE]
[NAME] __________
Affiant
SUBSCRIBED AND SWORN TO before me in the City of _______________ on
this day of [MONTH AND YEAR]_________________, affiant exhibiting before me his
Government Issued ID no. _______________ issued on [DATE}__________________ at
[PLACE OF ISSUANCE]_____________________.
[SIGNATURE]
[NAME]_______
Notary Public
Until [DATE]__________________
PTR No. [NUMBER] ____________
Issued at [PLACE]______________
On [DATE] ___________________
Doc. No.
Page No.
Book No.
Series of [YEAR] ___________.