Republic of the Philippines

REGIONAL TRIAL COURT

4th Judicial Region

Branch___

BATANGAS CITY

Bea A. Alonzo

Plaintiff,

-vs- Civil Case No. 1234567

For: Collection of Sum of Money

Julia B. Baretto

Defendant.

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

ANSWER

DEFENDANT HAZEL ANNE M. MANALO. by undersigned counsel, unto this Honorable Court most respectfully states
that:

1. Paragraphs one (1) to four (4) of the Complaint are admitted;

2. Paragraphs seven (7) and eight (8) of the Complaint are denied for lack of knowledge or information sufficient to
form a belief as to the veracity or falsity thereof, the allegations therein being matters known only to and are
within the control only of the plaintiff;

3. Paragraph six (6) 0f the Complaint is denied insofar as it alleges that the defendant owes the plaintiff a sum of
money and fails to pay the same. the truth being those alleged in the special and affirmative defenses part
hereinbelow:

SPECIAL AN D AFFIRMATIVE DEFENSES

1. The Defendant never received any verbal or written demand from the Plaintiff.
2. That no prior conciliation between the Defendant and the Plaintiff before the Barangay Lupon was made.
 PRAYER

WHEREFOR, PREMISES CONSIDERED, it is respectfully prayed to this Honorable Court the dismissal of the
Complaint for lack of merit with cost against the Plaintiff.

Other reliefs just and equitable under the premises are likewise prayed for.

Batangas City, Batangas, July 20, 2019.

TRIVEN P. CASTILLO

Counsel for the Defendant

Roll of Attorney No. 45969 PPR No. 123456: 01 02 01 /

Batangas City IBP Life Member Roll No. 445789/07 08 Ol /
Batangas City

MCLE Compliance No. [II 897656 / 12 10-01

VERIFICATION and CERTIFICATION OF NON FORUM SHOPPING

I, JULIA B. BARETO, of legal age. Filipino. married. and a resident of Brgy Sta. Clara, Batangas City, after having
been duly sworn to in accordance with law hereby depose and state that:

1. I am the defendant in the above stated case:

2. I have caused the preparation and filing of the foregoing Answer and have read the allegations therein,
and that they are true and correct of my personal knowledge and belief and based on authentic
documents;
3. I have not commenced any other action or proceeding involving the same issues before the Supreme
Court. Court of Appeals or any other tribunal or agency and. to the best of my knowledge. there is no such
action or proceeding pending before any tribunal;
4. If I should learn that a similar action or proceeding has been filed or is pending before the Supreme Court,
Court of Appeals or any other tribunal or agency. I undertake to report that fact within five [5) days
therefrom to this Honorable Court.

IN WITNESS WHEREOF. I have unto set my hand this July 20, 2019.

JULIA B. BARETO
Affiant

SUBSCRIBED AND SWORN to before me this July 20, 20019, Batangas City, affiant exhibiting to me her
driver‘s license with No. L03 654321 issued on May 2084, as competent proof of her
identity.

TRIVEN P. CASTILLO
 Notary Public
Valid Until December 31, 2019
Roll of Attorney No. 45969 FIR No. 123456: 01 02 01 / Batangas City
IBP Life Member Roll No. 445789/07 08 01 / Batangas City
MCLE Compliance No. 111 897656 / 12 10 01

Doc. No.: 49
Page No.: 8
Book No.: II
Series of 2015