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Republic of the Philippines

Regional Trial Court

Tuguegarao City

Defendant, trough the undersigned counsel, most respectfully file his answer in response to the
complaint of the plaintiff, to wit;


1. Paragraphs 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, of the complaint are denied for lack of
knowledge or information sufficient to form a belief as to the veracity or falsity thereof,
the allegations therein being matters known only to and are within the control of the
2. Paragraph 114 of the complaint is denied in so far as the taking of the plate number of
the motor vehicle is concerned.
3. In so far as the allegation in paragraph 14 about the alleged registration of the motor
vehicle in the name of James Mariano, the same is admitted.
4. Paragraph 15 is denied in so far as the witness identifying James Mariano being the
gunman but the plate number being registered in his name is admitted.

1. Between the date of December 14, 2017 and December 17, 2017 accused James
Mariano was not within the territory of the Philippines so as to involve him of the
offense charge, it is physically impossible for said accused to execute the acts charged.