REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

9th JUDICIAL REGION
Branch 16

Ivanah Ahlauwiee.,
Plaintiff., Sp. Proc. No. 01010
-versus-
Johniee Bravow
Defendant.,
x-------------------------------------------x

ANSWER
Defendant through counsel, by way of answer, respectfully states that:
1. He admits the allegations in paragraph 2 of the Complaint
regarding his personal circumstances;

2. He is without knowledge or information to form a belief as to truth

of the allegations in paragraphs 4, 5 and 6 of the Complaint.

3. He specifically denies each and every material allegation of the

complaint since it does not state a cause of action and is a shame
pleading.

COUNTERCLAIM

4. Defendant additionally submits that he is entitled to relief arising

from the filing of this malicious and baseless suit, as follows:

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 4.1 Moral Damages amounting to Sixty Thousand Pesos (P60,000)
because his name and reputation were besmirched by this
malicious and baseless suit.

4.2 Plaintiff has instituted the instant malicious suit which

compelled Defendant to engage the services of counsel, in order to
protect Defendant’s interests, for an agreed professional fee of
P300,000 plus an appearance fee of P5,000 per hearing.

4.3 Defendant also incurred other litigation expenses in the sum of

P60,000. For all said fees and litigation expenses, Plaintiff should
be adjudged liable to Defendant.

WHEREFORE, Defendant respectfully prays that judgment be

rendered in his favor by dismissing the Complaint and granting
Defendant’s counterclaim by awarding the defendant: (a) Sixty
Thousand pesos (P60,000) as Moral Damages, and (b) Three Hundred
Thousand Pesos (P300,000) plus Five Thousand Pesos (P5,000) for
every hearing attended by Defendant’s counsel as Attorney’s fees.

Other just and equitable reliefs are prayed for.

Zamboanga City, January 26,2020

ATTY. ALAYKA A. ANUDDIN

Counsel for Defendant
Roll of Attorneys No.: 54278
IBP No.: 13425; 3/14/2015; Zamboanga City
PTR N 762890; 6/5/2016; Zamboanga City
MCLE Compliance No.: M-45637; 9/21/2015

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Copy furnished through registered mail:

ATTY. MIA MARIELLE T. QUIJANO

Counsel for Petitioner
Roll of Attorneys No.: 41829
IBP No.: 1014730; 1/4/2016; Zamboanga City
PTR No.: 874058; 1/5/2016; Zamboanga City
MCLE Compliance No.: V-0011654; 11/25/2015

EXPLANATION

A copy of the foregoing answer was served on Plaintiff’s counsel by

registered mail due to time constraints and lack of messenger to effect
personal service.

ATTY. ALAYKA A. ANUDDIN

Lifetime IBP No. 76453; 10/9/11; Zamboanga City
PTR No. 1486225; 1/09/20, Zamboanga City
MCLE Compliance No. IV-000379; 3/18/2016
Roll of Attorneys No. 65789
alaykaanuddin@gmail.com

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