Beruflich Dokumente
Kultur Dokumente
GAIL L. AVILA,
Plaintiff,
ANSWER
COME NOW the defendants, through the undersigned counsel, to this Honorable
Court, by way of Answer to the complaint in the above-entitled case, most respectfully
aver that:
to the effect that the herein defendants refused to cede, transfer, and convey the subject
lot to the plaintiff, and to cause the transfer of the certificate of title in the name of the
latter for the reason that herein defendants had already executed in favor of the plaintiff
the deed of absolute sale covering the subject lot, as evidenced by a copy thereof, which
was already attached to the complaint as ANNEX “A” thereof; and, in addition, herein
defendants had already handed over to the plaintiff the Owner’s Duplicate Copy of the
Original Certificate of Title (OCT) No. 0-167, covering the lot in question, as proved by
her acknowledgment receipt thereof, copy of which is attached hereto and marked as
ANNEX “1;”
3. They have no more obligation to cause the transfer and registration of the
subject lot in the name of the plaintiff inasmuch as the herein defendants had already
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Answer
executed in her favor the deed of absolute sale covering the subject lot; and, in addition,
they had likewise turned over to her the Owners Duplicate Copy of OCT No. 0-167
complaint for lack of knowledge sufficient to form a belief as to the truth thereof; and,
5. For the filing of this baseless and unjustified complaint, herein defendants
were compelled to engage the services of counsel, for a fee; and for which, they
committed to pay the sum of P50,000.00, as acceptance fee, plus an honorarium in the
sum of P3,000.00 per court appearance; and, in addition, to incur litigation expenses in an
PRAYER
Honorable Court that judgment be rendered in favor of the defendants and against the
plaintiff:
2. Ordering the plaintiff to pay the herein defendants the sum of P50,000.00, as
for attorney’s fee, plus an honorarium of P3,000.00 per court appearance of their counsel;
3. Further, defendants pray for such other relief, just and equitable, under the
premises.
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Answer
Mat U. Lungin
Counsel for the Defendants
ACS Bldg., 43 Anonas Street
Project 2, Quezon City
Roll of Attorneys No. 23456
IBP Lifetime OR No. 00789
PTR No. 012345; 1-2-10; Q.C.
MCLE Compliance No. III
Tel. No. 425-26-99
Mobile Phone No. 0921-392-63-36
Atty. _______________
Counsel for the Plaintiff
___________________
___________________
EXPLANATION
(In Compliance with Section 11, Rule 13 of the 1997 Rules of Court)
Service of the foregoing Answer upon the plaintiff was done by registered mail,
instead of personal service, for practical reason due to distance of the respective office of
parties’ respective counsel.
Mat U. Lungin