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Answer With Affirmative Defenses

1) Pauleen P. Patria is being sued by Denice D. Demetri for the sum of 1 million pesos that Patria incurred as a debt and executed a promissory note for. 2) Patria denies owing any money and claims to have already paid 500,000 pesos on November 1, 2019 and another 500,000 pesos on January 10, 2020 to Demetri's agent Joyce J. Juagan. 3) Patria is countersuing for 10,000 pesos in legal fees and 20,000 pesos in exemplary damages, claiming the original suit was baseless.

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Jan-Lawrence Olaco
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845 views4 pages

Answer With Affirmative Defenses

1) Pauleen P. Patria is being sued by Denice D. Demetri for the sum of 1 million pesos that Patria incurred as a debt and executed a promissory note for. 2) Patria denies owing any money and claims to have already paid 500,000 pesos on November 1, 2019 and another 500,000 pesos on January 10, 2020 to Demetri's agent Joyce J. Juagan. 3) Patria is countersuing for 10,000 pesos in legal fees and 20,000 pesos in exemplary damages, claiming the original suit was baseless.

Uploaded by

Jan-Lawrence Olaco
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOC, PDF, TXT or read online on Scribd
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Republic of the Philippines

REGIONAL TRIAL COURT


11th Judicial Region
Branch 16
Davao City

DENICE D. DEMETRI
Plaintiff,

-versus- Civil Case No. 7866


For: Sum of Money

PAULEEN P. PATRIA
Defendant.
x----------------------------------------------/

ANSWER with AFFIRMATIVE DEFENSES

Defendant, by counsel, respectfully avers that:

ADMISSION/DENIAL

1. Paragraphs 1 and 2 of the Complaint are admitted insofar as they


relate to the personal circumstances of the parties;

2. Paragraphs 3 and 4 are admitted insofar as it states that the defendant


incurred indebtedness of ONE MILLION PESOS (P1,000,000.00) and
executed promissory note in favor of the plaintiff;

3. Paragraphs 5 is specifically denied the truth being that the allegation


is maliciously false and that the defendant had already paid to the
plaintiff‘s agent JOYCE J. JUAGAN the following amounts: FIVE
HUNDRED THOUSAND PESOS (P500,000.00) on November 1,
2019 and another FIVE HUNDRED THOUSAND PESOS
(P500,000.00) on January 10, 2020 (photocopies of payment
receipts are hereto attached as annex A-1 and A-2);
4. Paragraph 6 is neither confirmed nor denied, not being statements of
ultimate facts, but the reliefs demanded by the plaintiff.

AFFIRMATIVE DEFENSE

5. That the pleading asserting the claim states no cause of action;

6. That the claim or demand set forth in the plaintiff’s complaint has
been paid;

BY WAY OF COUNTER CLAIM

7. As a proximate cause in filing this baseless suit, defendant engaged


the services of the undersigned counsel in the contractual sum of TEN
THOUSAND PESOS (P10,000.00), which amount should be assessed
against plaintiff, exclusive of appearance fee of counsel pegged at
ONE THOUSAND PESOS (P1,000.00) per hearing;

8. In order to serve as a lesson and a forewarning against plaintiff who


have the temerity to institute baseless suits, rather indiscriminately,
the award of exemplary damages in the amount of TWENTY
THOUSAND PESOS (P20,000.00) for defendant is warranted

PRAY E R

WHEREFORE, it is respectfully prayed of this Honorable Court


that, after due notice and hearing, the instant case be DENIED, for
having been anchored on distorted facts, and for utter lack of merit.

Defendant prays for such other reliefs deemed just and equitable
under the circumstances.

RESPECTFULLY SUBMITTED.

Done. Davao City, Philippines. 10th day of February 2020.

(sgd.)
ATTY. JACOBO J. JUMAW
Counsel of Defendant
Roll No. 54321/January 5, 2020
IBP Lifetime No. 09190
PTR No. 1276543, issued on May 05, 2019 at Davao City
MCLE No. IV-004222, issued on April 10, 2019 at Davao City
#60 Magallanes Street, Davao City

REPUBLIC OF THE PHILIPPINES)


CITY OF DAVAO ) S.S.
x----------------------------------------------x

VERIFICATION AND CERTIFICATION

I, PAULEEN P. PATRIA, of legal age, Filipino citizen, and a resident of


Dr. 3, Sunnypoint Apartelle, Brgy. Ma-a, Davao City, under oath, depose and
state:

1. I am the defendant in the above-captioned case, I caused the preparation


of the foregoing Answer and have read and understood the contents of the
same; and that

2. All the allegations therein are true and correct to the best of my personal
knowledge and based on authentic documents.

IN WITNESS WHEREOF, I have signed this instrument on the 10th


day of February 2020, in the City of Davao, Philippines.

(sgd.)
PAULEEN P. PATRIA
Affiant

SUBSCRIBED AND SWORN TO before me, this 10th day of February


2020, personally appeared to me a certain PAULEEN P. PATRIA exhibiting
to me her Community Tax Certificate No. 002945 issued on January 2020 at
Davao City, Philippines and his Driver’s License No. 5233 issued on
November 9, 2019 at Davao City, Philippines.

Doc. No. __ ;
Page No. ___ ;
Book No. ___;
Series of ___ .

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