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Answer to the Complaint Sample

REPUBLIC OF THE PHILIPPINES


METROPOLITAN TRIAL COURT
City of Manila
Branch 1
MICHAEL BADIRRI,
Plaintiff,

-versus- CIVIL CASE NO. 12345

EDIL FRANCISCO,
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 2 only insofar as his personal circumstances are
concerned;
2. That he ADMITS his obligation of paying the monthly installments cited in paragraph 3 of the complaint,
but DENY the rest of the allegations therein as said defendants obligation to plaintiff is not for the
exercise of a right to repurchase but for the amortization of a loan that he acquired from the plaintiff at
an interest of 12% per annum;
3. That defendant is without knowledge or information sufficient to form a belief as to the veracity of the
averments in paragraph 4 of the complaint;
4. That defendant does not, at the moment, have all the records of payments he made to plaintiff, so that
he also does not have information sufficient to form a belief as the truth of the allegations in paragraph
5 of the complaint and, therefore, DENY them.
WHEREFORE, the defendant respectfully prays that the complaint be dismissed with costs
against the plaintiff.

Other relief and remedies as may be deemed just and equitable under the premises are likewise
prayed for.

City of Manila, September 27, 2012.

GACUTAN AND SALAZAR LAW OFFICE


Counsel for the Defendant
Suite 258 The Tower
Malate, Manila

By:
ARVIN GACUTAN
Roll No. 98765
IBP No, 12345/1-3-2012/Manila
PTR No. 34567/1-3-2012/Manila

Copy furnished:
ATTY. FRETTI LAUREL
Counsel for the Plaintiff
Unit 1234 Laurel Building
Sampaloc, Manila

EXPLANATION

Copy of the foregoing ANSWER was served to plaintiffs counsel by registered mail due to time
and distance constraints and for lack of the undersigneds staff who can serve the same in person.