REPUBLIC OF THE PHILIPPINES

12TH Judicial Region

REGIONAL TRIAL COURT
Branch 32,
Cotabato City

JUAN A. DE LA CRUZ, CIVIL CASE NO. 2019-1020

Plaintiff,

-versus-
CANCELLATION/ANNULMET
OF TITLT, DEED SALE AND
DAMAGES AND ATTORNEY’S
FEE
PETRA DE LA CRUZ,
REGISTER OF DEEDS
OF COTABATO CITY as
represented by AL V. MAGNO,
Defendants.
Defendant.
x--------------------------------------------x

ANSWER

COME NOW, defendant PETRA DE LA CRUZ, assisted by the

undersigned counsel unto this Honorable court most respectfully
show:

1. The defendant admits the contents of paragraph 1 and 2 insofar as

the plaintiff’s and defendant’s personal circumstances is
concerned;

2. The defendant admits the allegations in paragraph 3 and 4 of the

complaint;

3. That defendant specifically denies the allegations of paragraph 5,

6, 7 and 8 of the complaint are specifically denied for being mere
conclusions of law and fact;

4. That the allegation contain in paragraphs 9, 10, 11, 12, 13, 14 15

and 16 of the complaint are specifically denied for being
conclusion of the law, and shall be more particularly pleaded in the
affirmative defences herein after set forth;
 AFFIRMATIVE DEFENSES

1. That the defendant was the real owner of the question property
evidence by the Deed of Sale executed between the Plaintiff and
Defendant, this fact known to the plaintiff, on June 21, 2004
executed by plaintiff in favor of defendant as the subject of such
deed of sale, marked as ANNEX 1;

2. That plaintiff’s here seeking the Annulment of the title on the

ground that the issuance of the same was tainted with false
pretense based on the document.

COUNTER-CLAIM

1. That this instant action is nothing except act of harassment,

maliciously designed by the plaintiff against the defendant.
Which the latter suffered besmirch reputation, mental anguish,
sleepless nights due to the filling of the baseless complaints by the
plaintiff and claimed Fifty Thousand Pesos (Php 50,000.00) by
way of moral damages.

2. That he engages the services of an attorney at law to protect his

interest and incurred Thirty Thousand Pesos (Php 30,000.00) as
attorney’s fees and Ten Thousand Pesos (Php 10,000.00) as cost of
litigation.

Prayer

a) WHEREFORE, premises considered defendant, most respectfully

prayed of this Honorable Court that judgement be rendered:

b) Dismissing the complaint for utter lack of merit and cause of

action.

c) Ordering the plaintiff to pay the defendant moral damages,

attorney’s fees and cost of litigation as prayed for in the preceding
paragraph, and

d) And such other relief as may be deemed just and equitable under
the circumstance.
 Respecfully submitted, City of Cotabato, this 29th day of July 2019.

ATTY. MENNALDZ A. AMILHASAN

Counsel for the Defendant
Roll No. 98765
IBP No, 12345/1-3-2019
PTR No. 34567/1-3-2019/ Cotabato City
MCLE COMPLIANCE CERTIFICATE NO. 556678
Door 2, Alnor Bldg.,
Cotabato City

REQUEST

The clerk of court

Regional Trial Court
Branch 32
Cotabato City

Greetings:

Please submit the foregoing ANSWER to this Honorable court upon

the filing thereof for its consideration.

MENNALDZ A. AMILHASAN
Counsel for the defendant

PROOF OF SERVICE AND EXPLAINATION

Service of this pleadings are done thru registered mail due to distance and
lack of manpower to effect personal service.

MENNALDZ A. AMILHASAN
Counsel for the defendant

Copy furnished:

ATTY. ABOGADO K. PILIPINO

Cotabato City