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Republic of The Philippines: Defendant

The defendant files an answer to the plaintiff's complaint with affirmative defenses. The defendant admits some facts of the complaint but argues improper venue. The defendant and plaintiff's primary addresses are in different cities, so the case should be dismissed or transferred due to improper venue. The defendant requests dismissal or other equitable relief.

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Suju Budol
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134 views

Republic of The Philippines: Defendant

The defendant files an answer to the plaintiff's complaint with affirmative defenses. The defendant admits some facts of the complaint but argues improper venue. The defendant and plaintiff's primary addresses are in different cities, so the case should be dismissed or transferred due to improper venue. The defendant requests dismissal or other equitable relief.

Uploaded by

Suju Budol
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd
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REPUBLIC OF THE PHILIPPINES

FOURTH JUDICIAL REGION


REGIONAL TRIAL COURT
City of Antipolo
Branch 97

SAM CONSTRUCTION AND GENERAL SERVICES, INC.

Plaintiff,

- versus – CIVIL CASE NO. 15-10600


For: COLLECTION FOR SUM OF.
MONEY
WITH DAMAGES

C BUILD PLUS CORPORATION

Defendant,

X————————————————X

ANSWER WITH AFFIRMATIVE DEFENSES

Defendant, thru the undersigned counsel, and unto this Honoroble Court, respectfully
avers that:
1. Defendant admits the averment in paragraphs one (1) and two (2) of the complaint
insofar as they relate to the personal information of the parties;
2. Defendant likewise admits that it engaged the services of herein plaintiff, as
averred in paragraph six (6). As evidenced by the Purchase Order representing
work description and Contract Duration as received by the plaintiff on December
10, 2013;

AFFIRMATIVE DEFENSE

3. Defendant, thru counsel, moves for the dismissal of the complaint on the ground
of improper venue;
4. The material provision on venue of personal actions provided in Section 2 of Rule
4 of the 1997 Rules of Civil Procedures reads as follows:
“Section 2. Venue of personal actions – All other actions may be
commenced and tried where the plaintiff or any of the principal plaintiff
resides, or where the defendant or any of the principal defendants resides,
or in the case of a non-resident defendant where he may be found, at the
election of the plaintiff.”
5. As averred in the complaint and evidenced by the Articles of Incorporation of both
the plaintiff and the defendant, their primary business address is at Marilao,
Bulacan and Bonifacio Global City, Taguig, respectively.

PRAYER

WHEREFORE, Defendant respectfully prays that herein complaint be ordered


dismissed on the ground of improperly laid venue.

Other equitable reliefs are likewise prayed for.

Taguig City, Philippines, 18 February 2022


Guillian Labampa
Counsel for the Defendant
Taguig City, Philippines

VERIFICATION AND CERTIFICATION AGAINST NON-FORUM SHOPPING

I, __________, Filipino, of legal age, with office address at Bonifacio Global City, Taguig
and representing C Build Plus Corporation, a domestic corporation duly organized and
exisiting by virtue of the Philippine laws and with principal office address at Bonifacio
Global City, Taguig. After being duly sworn in accordance with law depose and say that:

1. I am the authorized representative of C Build Plus Corporation (hereafter, the


defendant), and from which the Corporation will file Answer with Affirmative
Defense. I have been duly authorized to act as representative of the
Corporation pursuant to a Secretary Certificate dated _________;
2. I have caused the preparation of the foregoing Petition;
3. I have read the allegations contained therein; and
4. I certify that they are true and correct of my personal knowledge or based on
authentic records.
In witness whereof, I have hereunto set my hand this 18th day of February 2022, at Taguig
City, Philippines.

Affiant

SUBSCRIBED AND SWORN to before me this_________, affiant exhibited to me her


________, issued at _________ on ________ and valid until ____________.

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