REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

MUNICIPAL TRIAL COURT
Manila, Branch 1

Tony’s Stark Inc.,

Plaintiff,
CIVIL CASE NO. 12368
For Unlawful Detainer
-versus-

Captain America
Defendant,
x------------------------------------------x

ANSWER WITH SPECIFIC DENIAL AFFIRMATIVE AND NEGATIVE DEFENSES

AND CROSS CLAIM
NOW COMES the defendant in the above entitled case, and to this
Honorable Court most respectfully alleges:
1. Defendant admits the averment in paragraph 1,2 and 3 of
the complaint;
2. Defendant specifically denies the allegation in paragraph 4
of the complaint, the truth being that defendant, a lawful
lessee of unit 45 of the apartment complex owned by herein
plaintiff, has been diligently paying monthly rentals ever
since defendant had become an occupant thereof;
3. That for over a decade, defendant had been paying monthly
rentals to a certain Alicia keys, the supposed book keeper of
herein plaintiff.
By way of special and affirmative defenses, defendant avers:
1. While plaintiff did in fact send several notices to defendant
to settle the rentals, said rentals, however, have been paid
by defendant to Alicia Keys, who has been collecting said
rent from defendant ever since the latter has moved to the
apartment complex;
 2. That Alicia Keys had been collecting rentals from defendant
as she was the book keeper of the plaintiff and was
introduced to defendant as such;
3. That Alicia Keys was introduced to defendant by the
plaintiff as his book keeper and was tasked by plaintiff to
collect rent from defendant.
By way of counterclaim, defendant alleges:
1. That by virtue of this unwarranted and malicious act initiated
by the plaintiff, defendant was forced to engage counsel in
the sum of P10,000.00;
2. That defendant had also suffered loss of income as plaintiff
had cut off the water supply of the apartment unit of the
defendant forcing him to close his mineral water for 2 weeks.
WHEREFORE, it is respectfully prayed that the complaint be dismissed
and defendant be awarded the amount of P500,000.00
Other equitable reliefs are likewise prayed for.
Manila, Philippines, July 17, 2018.
Spider Man
Attorney for the Defendant
P.T.R. No. 123456 Date & Place of
Issue 11111 IBP O.R. No.153556 Date &
Place of Issue_____