REPUBLIC OF THE PHILIPPINES

METROPOLITAN TRIAL COURT

TACLOBAN CITY

BRANCH 7

MICHELLE C. BASAL,
Plaintiff,
CIVIL CASE No. 98765
-versus- FOR: Unlawful Detainer

PIA O. WORKSBACK,
Defendant.

x-----------------------------------x

ANSWER

Comes now the DEFENDANT, assisted by counsel, hereby depose that:

1. She admits the contents of paragraph 1 and to insofar as her

personal circumstances are concerned.
2. She admits that a contract of lease has been entered into between
parties.
3. She admits the contents of paragraph 3 and 4 in the complaint
submitted by the plaintiff.
4. The allegation of the plaintiff in paragraph 6 and 7 is however
DENIED. Contrary to the assertion of the plaintiff, the defendant did
not receive any notice to evict. In fact, there was no way that the
defendant and the plaintiff could have confronted in the day when the
alleged demand letter was delivered as the former was in fact in
Japan on the day of October 5, 2017. Attached herewith as “Annex B”
is the Philippine Airlines ticket and boarding pass of the defendant
evidencing the trip to Japan on the said date;
5. The defendant further avers that her there are no other persons living
in the premises of her residence on the day that the alleged notice
was delivered for she has no immediate families living in the
Philippine since April 2017.

WHEREFORE, the defendant respectfully prays that the complaint be

dismissed with costs against the defendant and other relief and
remedies that the court may deem proper.

August 5, 2019 City Tacloban.

ATTY. MELANI C. CALCETA

Counsel for Defendant
Uytingkok Buildingm,Salazar Street, Tacloban City
MCLE NO:12345/060620109
Roll No: 12345/Tacloban City
IBP No. 12345/ Tacloban City
PTR No. 54321/Tacloban City

VERIFICATION/CERTIFICATION OF FORUM SHOPPING

Republic of the Philippines )

City of Tacloban ) S.S.

I, PIA O. WORKSBACK, of legal age, Filipino citizen, single and

resident
of Brgy. 74 Lower Nula-Tula Tacloban City, after having been duly
sworn to in accordance with law do hereby depose and say:
1. That I am the defendant in the above-entitled case;
2. That I have caused the preparation of the foregoing complaint and
have read the allegations contained therein;
3. The allegations in the said complaint are true and correct of my
own knowledge and authentic records;
4. I hereby certify that I have not commenced any other action or
proceeding involving the same issues in any court, tribunal or quasi-
judicial agency and, to the best of my knowledge, no such other
action or claim is pending therein;
5. That if I should learn thereafter that a similar action or proceeding
has been filed or is pending, I hereby undertake to report that fact
within five (5) days therefrom to the court or agency where the
original pleading and sworn certification contemplated herein have
been filed;
6. I executed this verification/certification to attest to the truth of the
foregoing facts and to comply with the provisions of Adm. Circular No.
04-94 of the Honorable Supreme Court.

IN WITNESS WHEREOF, I have hereunto affixed my signature this

5th of August, 2019, in the City of Tacloban.

PIA O. WORKSBACK

SUBSCRIBED AND SWORN to before me this 4th day of August,

2019, in the City of Tacloban, affiant exhibiting to me his Driver’s
License No. 12345 issued by the Land Transportation Office on April
8, 2018 at the City of Tacloban.

ATTY. Note Ted

Notary Public
My Commission Expires Dec. 31, 2019
Roll of Attorney No. 34567
IBP No. 12345/2-5-12/Manila
PTR No. 87654/12-22-11/Manila
MCLE 12345/050220
Doc. No. ________
Page No. _______
Book No. _______
Series of 2019.