REPUBLIC OF THE PHILIPPINES

METROPOLITAN TRIAL COURT

City of Malaybalay
Branch 8

PETER PANDA ACOSTA, CIVIL CASE NO. 54321

          Plaintiff,

            -- versus -- FOR:
COMPLAINT FOR
MARK BENE JACOBS, SUM OF MONEY
          Defendant.

x………………………………………………………………………………………………………..x

ANSWER WITH CROSS-CLAIM

DEFENDANT PETER PANDA ACOSTA, through the undersigned

counsel and unto this Honorable Court, most respectfully avers that:

1. He ADMITS paragraph 2 of the complaint;

2. He DENIES paragraph 3 of the complaint, the truth being that it

was the defendant MARK BENE JACOBS who applied for and
exclusively benefited from the loan with the plaintiff, answering
defendant acting as mere co-signer in the promissory note to
accommodate defendant MARK BENE and to guarantee the loan;

3. He lacks knowledge or information sufficient to form a belief as to

the truth of the allegations contained in paragraphs 3, 4, and 5 of
the complaint and therefore, specifically DENIES the same;

SPECIAL/AFFIRMATIVE DEFENSES

4. Without the knowledge and consent of answering defendant, the

principal condition of the loan was changed and the term of
payment thereof was unreasonably extended by the plaintiff, to
the prejudice of answering defendant;
 5. There was undue delay on the part of the plaintiff in enforcing the
payment of the obligation, and the loan could have been paid
immediately at maturity had there been prompt and timely
notification to answering defendant of the non-payment of the
loan by defendant MARK BENE;

CROSS-CLAIM AGAINST HIS CO-DEFENDANT

6. Defendant MARK BENE should reimburse answering defendant

on any and whatever amount the latter may be held answerable
or which he may be ordered or suffered to pay under and by
virtue of the present action in favor of the plaintiff, answering
defendant not having benefited whatsoever from the loan which
defendant MARK BENE obtained from the plaintiff;

7. That defendant MARK BENE should pay plaintiff directly and fully
on the amounts claimed by the latter in its complain he having
benefited directly and exclusively from the transaction alleged in
the complaint;

WHEREFORE, premises considered, answering defendant

respectfully prays to the Honorable Court to render judgment as
follows:

1. By dismissing the complaint against answering defendant;

2. By ordering defendant MARK BENE to pay directly and fully to

the plaintiff the amounts claimed by the latter in the complaint;

3. By ordering defendant MARK BENE to pay answering defendant

for any and whatever amounts the latter may be held liable to or
be ordered or suffered to pay plaintiff under and by virtue of the
plaintiff’s claim in the present action.

Answering defendant prays such other relief and remedies as may

be deemed just and equitable under the premises.

City of Malaybalay, 10 January, 2020.

BARROSO AND ASSOCIATES LAW OFFICE

Counsel for PETER PANDA ACOSTA
Malaybalay City
 By: Sgd.
DANICA ANTHEA G. BARROSO
  Roll No. 12345
    IBP No. 23456/1-18-2020
   PTR. No. 34567/1-18-2020

Copy furnished:

ATTY. ROB JANE M. SOLITO

Barangay Sumpong, Malaybalay City, Bukidnon

Republic of the Philippines )

Province of Bukidnon           ) S.S.
City of Malaybalay )

VERIFICATION AND CERTIFICATION

AGAINST NON-FORUM SHOPPING

I, PETER PANDA ACOSTA, of legal age, Filipino citizen, married

and a resident of Barangay Casisang, Malaybalay City, Bukidnon, after
having duly sworn to in accordance with law, do hereby depose and say
that:

1. I am the defendant in the above-entitled case;

2. I have caused the preparation of the foregoing ANSWER and have
read the allegations contained therein;
3. The allegations in said Answer are true and correct of my own
knowledge and based on 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. If I should thereafter learn 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

th
10 day of January 2020, in the City of Malaybalay.

Sgd.
PETER PANDA ACOSTA
Affiant

SUBSCRIBED AND SWORN to before me this 10 th day of January

2020, in the City of Malaybalay, affiant exhibiting to me his TIN No. 456-
789-123 issued on 05 April, 2011.

Doc. No. 12:

Page No. 01:
Book No. 02:
Series of 2020