REPUBLIC OF THE PHILIPPINES

6TH JUDICIAL REGION

REGIONAL TRIAL COURT
BRANCH 30
ILOILO CITY

ALEXANDER SISON, Civil Case No. 93113

Plaintiff FOR: COLLECTION FOR A
SUM OF MONEY WITH
DAMAGES
- versus -

JUAN JAMERO,
Defendant

X-------------------------------------X

ANSWER

Defendant, through the undersigned counsel unto this Honorable Court,

hereby respectfully avers that:

1. Paragraphs one (1) and two (2) of the Complaint is admitted;

2. Paragraph five (5) is 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 only of the
plaintiff; and

3. Paragraphs three (3) and four (4) of the complaint is denied insofar as
it alleges that the defendant has not made any payment and as of December
10, 2016, the total amount due is one million pesos (PHP 1,000,000.00), with
an accrued interest of thirty thousand pesos (PHP 30,000.00) as stated
therein, the truth being alleged in the special and affirmative defenses part
herein below.

SPECIAL AND AFFIRMATIVE DEFENSES

1. On January 03, 2008, plaintiff and defendant met in defendant’s

vacation home in La Paz, Iloilo City, to transact business. During their
negotiations, plaintiff agreed to let defendant borrow a sum of one million
pesos (PHP 1,000,000.00).

2. On January 03, 2009, when the note became executory, defendant

delivered to plaintiff the sum of one million pesos (PHP 1,000,000.00) and
the accrued interest amounting to one hundred twenty thousand pesos (PHP
120,000.00).

3. However, plaintiff refused to accept payment. As a consequence

thereof, and as advised by counsel, defendant consigned the aforementioned
amounts to Branch 29 of the Regional Trial Court of Iloilo City, as evidenced
by “Annex-1”, “Decision of Consignation.”

4. That between January 03, 2009 up to the present date, defendant

repeatedly informed plaintiff that he had consigned the amount due and its
accrued interest to the Regional Trial Court, Branch 29, of Iloilo City. But,
for some reason, within the last 9 years, plaintiff failed to do so.

COMPULSARY COUNTERCLAIM

1. By reason of the abuse of right committed by the plaintiff and by

reason of the instant precipitate and unfounded suit, the defendant was
constrained to hire the services of a lawyer to defend her rights and interests
for a professional fee of one hundred thousand pesos (₱100,000.00) and two
thousand pesos (₱2,000.00) per court appearance;

2. Similarly, the plaintiff’s unfounded suit has caused the defendant

mental anguish, wounded feelings, sleepless nights, serious anxieties, and
other similar sufferings for which the defendant claims moral damages of two
hundred thousand pesos (₱200,000.00).

PRAYER

WHEREFORE, PREMISES CONSIDERED, it is respectfully prayed

to this Honorable Court the dismissal of the complaint for lack of merit with
costs against the plaintiff; and that the defendant’s compulsory counterclaim
be granted, i.e., moral damages of two hundred thousand pesos (₱200,000.00),
attorney’s fees of one hundred thousand pesos (₱100,000.00), and two
thousand pesos (₱2,000.00) per court appearance and costs of suit.

Other reliefs and remedies deemed just and equitable under the
foregoing premises are likewise prayed for.

Iloilo City, January 8, 2018.

ATTY. JOSHUA JOHN A. GRANADA

NOTARY PUBLIC for Province of Iloilo
Commission Serial No. 157775
Until December 3, 2018
Granada and Javier Law Offices
Roll of Attorney 082557
IBP No. 312421/04/04/14/Iloilo City
PTR No. 397564/ Province of Iloilo
MCLE No. V-19022568
REPUBLIC OF THE PHILIPPINES)
PROVINCE OF ILOILO ) SS.
x----------------------------x

VERIFICATION AND CERTIFICATION

I, JUAN JAMERO, of legal age, after having been duly sworn in

accordance with law, depose and state that:

1. I am the petitioner in the above-stated case;

2. I caused the preparation of the foregoing petition;

3. I have read the contents thereof and the facts stated therein are true and
correct to my personal knowledge and/or on the basis of documents and
records in my possession;

4. I have not commenced any other action or proceeding involving the

same issue in the Supreme Court, the Court of Appeals, or any other
tribunal or agency;

5. To the best of my knowledge and belief, no such action or proceeding

is pending in the Supreme Court, the Court of Appeals, or any other
tribunal or agency; and

6. If I should thereafter learn that a similar action or proceeding has been

filed or is pending before the Supreme Court, the Court of Appeals, or
any other tribunal or agency, I undertake to report that fact within five
(5) days therefrom to this Honorable Court.

________________________
JUAN JAMERO
Affiant
TIN 49932-442; Iloilo City
 ACKNOWLEDGMENT

(Republic of the Philippines)

City of Iloilo) S.S.

SUBSCRIBED AND SWORN to before me, a Notary Public, for and

in the City of Iloilo, this 2nd day of January 2018 personally appeared:

Name Identification Card Issued On/At

Juan Jamero TIN ID Iloilo City, 03/28/16

all known to me to be the same person who executed the foregoing instrument
and hereby acknowledged to me that the same is their free and voluntary act
and deed.

This instrument consisting of four (4) pages, including this page on

which this acknowledgment is written refers to a COLLECTION FOR A
SUM OF MONEY WITH DAMAGES and has been signed by the party and
sealed with my notarial seal.

WITNESS MY HAND AND NOTARIAL SEAL.

Doc. No.____; ATTY. JOSHUA JOHN A. GRANADA

Page No.____; NOTARY PUBLIC for Province of Iloilo
Book No.____; Commission Serial No. 157775
Series of 20___. Until December 3, 2018
Granada and Javier Law Offices
Roll of Attorney 082557
IBP No. 312421/04/04/14/Iloilo City
PTR No. 397564/ Province of Iloilo
MCLE No. V-19022568