Republic of the Philippines

4TH JUDICIAL REGION

Regional Trial Court
Branch 23
Quezon City

FE S. SOLANOY, Civil Case No. _____________

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

PEDRO P. PASCUAL,
Defendant
x -----------------------x

ANSWER

DEFENDANT PEDRO P. PASCUAL, by undersigned counsel, unto

this Honorable Court most respectfully states that:

1. Paragraphs one (1) to four (4) of the Complaint are admitted;

2. Paragraph five (5) is denied, the truth being that the obligation has
been partially paid already;

3. Paragraphs six (6) to eight (8) 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 only of the plaintiff;

4. Paragraph nine (9) of the Complaint is admitted;

SPECIAL AND AFFIRMATIVE DEFENSES

1. On June 17, 2018, the Defendant paid the Plaintiff and gave Five
Hundred Fifty Thousand Pesos (Php550,000.00), as evidenced by an
acknowledgment receipt signed by the Plaintiff, attached herein, marked as
“Annexed A” and made an integral part hereto.

2. That the main reason the Plaintiff claims that debt is not yet paid, is
due to the two (2) percent interest of the first promissory note which we
agreed to be paid by the Defendant on December 20, 2020 as stated also in
the acknowledgment receipt signed by the Plaintiff, attached herein, marked
as “Annexed A” and made an integral part hereto.

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Complaint
 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 his rights and interests
for a professional fee of Twenty-Thousand Pesos (Php20,000.00) and Three
Thousand Pesos (Php3,000.00) 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
Fifty Thousand Pesos (Php50,000.00).

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 Fifty Thousand Pesos (Php
50,000.00), attorney’s fees of Twenty-Thousand Pesos (Php20,000.00), and
Three Thousand Pesos (Php3,000.00) per court appearance and costs of suit.

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

Quezon City, Manila. July 30, 2020.

ATTY MARK REGIDOR M. COLEGIO

Counsel for Defendant
Roll of Attorney No. 45969
PTR No. 123456; 01-02-20 / Quezon City
IBP Life Member Roll No. 445789/07-08-20 / Quezon City
MCLE Compliance No. III-897656 / 12-10-20

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Complaint
REPUBLIC OF THE PHILIPPINES)
METRO MANILA ) SS.
x----------------------------x

VERIFICATION AND CERTIFICATION

I, PEDRO P. PASCUAL of legal age, Filipino, single, and a resident

of 456 Santol St. Brgy Balite, Quezon City, Philippines, after having been
duly sworn to in accordance with law, hereby depose and state that:

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

2. I have caused the preparation and filing of the foregoing

Answer and have read the allegations therein, and that they are true and
correct of my personal knowledge and belief and based on authentic
documents;

3. I have not commenced any other action or proceeding involving

the same issues before the Supreme Court, Court of Appeals or any other
tribunal or agency and, to the best of my knowledge, there is no such action
or proceeding pending before any tribunal;

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

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

IN WITNESS WHEREOF, I have hereunto set my hand this July

30, 2020, Quezon City, Manila.

PEDRO P. PASCUAL
Affiant

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Complaint
 SUBSCRIBED AND SWORN to before me this July 30, 2020,
Quezon City, affiant exhibiting to me her driver’s license with No. L03-
654321 issued on May 2020, as competent proof of her identity.

ATTY MARK REGIDOR M. COLEGIO

Notary Public
Valid Until December 31, 2020
Roll of Attorney No. 45969
PTR No. 123456; 01-02-20 / Quezon City
IBP Life Member Roll No. 445789/07-08-20/Quezon City
MCLE Compliance No. III-897656 / 12-10-20

Doc. No.: 49
Page No.: 8
Book No.: II
Series of 2020

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Complaint