Republic of the Philippines Metropolitan Trial Court City of Iriga Branch 17

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ALICE DY YAN, Plaintiff, - versus YOKO NGA, Defendant, x --------------------------------- x ANSWER WITH COUNTERCLAIM DEFENDANT, by counsel, respectfully states that:Admissions/Denials1. 1. He admits the contents of paragraph 1, 3 and 7. 2. He admits the contents of paragraph 2 only where it states that a Contract of Leasewas entered into but specifically denies that the contract reflects the true intent of theparties as explained in the Affirmative Defenses below. 3. He admits the contents of paragraph 4 and 5 as to the fact that demand to vacate wasmade but specifically denies its contents as to the truth of the reasons for the letter forlack of knowledge sufficient to form a reasonable belief as to its truth or falseness. 4. He specifically denies the contents of paragraph 6 for the reason stated in theAffirmative Defenses stated below.Affirmative Defenses. 5. Defendant reiterates, repleads and incorporates by reference all the foregoing in so faras they are material and additionally submit that the Complaint should be dismissedbecause: 6. The Complaint fails to state a cause of action as the Contract of Lease (ANNEXA) was, before its expiration, superceded by a Deed of Absolute Sale wherebyplaintiff sold to defendant the parcel of land in question, a copy of which isattached as ANNEX 1. 7. Defendant reiterates, repleads and incorporates by reference all the foregoing insofaras they are material and additionally submit that he is entitled to relief arising fromthe filing of this malicious and baseless suit, as follows: 8. Moral damages amounting to One Hundred Thousand Pesos (PHP 100,000.00)because his name and reputation were besmirched by this malicious and baselesssuit. 9. Attorneys Fees amounting to Fifty Thousand Pesos (PHP 50,000.00) because hewas compelled to secure services of counsel to vindicate his legal rights. WHEREFORE, Defendant respectfully prays that judgment be rendered in his favor by dismissing the Complaint and granting defendantcounterclaim by awarding defendant:(a) One Hundred Thousand Pesos as Moral Damages, and (b) Fifty Thousand Pesos asAttorneys Fees.Other just and equitable reliefs are prayed for. July 11, 2012, City of Iriga Civil Case No. 0297 For: Unlawful Detainer

ATTY. VINCENT DANNIE B. BOLO 17 Verbena St., San Francisco, Iriga City Roll No. 0001 P.T.R. No. 0002, 12/31/2012, Manila. IBP No. 0003, 12/31/2012, Manila.MCLE Compliance No. 1234 SUBSCRIBED AND SWORN to before me, this 11th day of July, 2012 in the City of Iriga, affiant exhibiting before me his Community Tax Certificate No. 123456, issued at IrigaCity on March 1, 2012.

ATTY. JANE ABLAZA NOTARY PUBLIC for Iriga City 15 Carnation St., DRJVillage, San Nicolas, I.C. Until Dec. 31, 2012 Roll No. 0001 P.T.R. No. 0002, 12/31/2007, Manila. IBP No. 0003, 12/31/2007, Manila. MCLE Compliance No. 1234 Serial No. of Commission: 07-11111 Doc. No. 9; Page No. 8; Book No. I; Series of 2012.

VERIFICATION AND CERTIFICATION AGAINST FORUM SHOPPING I, Yoko Nga, of legal age, do hereby state that: I am the defendant in the case filed byAlice Dy Yan for ejectment; in response, I have caused the preparation of this Answer withCounterclaim; I have read its contents and affirm that they are true and correct to the best of myown personal knowledge; I specifically deny the genuineness and due execution as well as thebinding effect of the actionable documents pleaded by plaintiff; I hereby certify that there is noother case commenced or pending before any court involving the same parties and the same issueand that, should I learn of such a case, I shall notify the court within five (5) days from mynotice. IN WITNESS WHEREOF, I have signed this instrument on April 28,2010 Baguio city. SUBSCRIBED AND SWORN to before me, this 11th day of July, 2012 in the City of Iriga, affiant exhibiting before me his Community Tax Certificate No. 123456, issued at IrigaCity on March 1, 2012.

ATTY. JANE ABLAZA NOTARY PUBLIC Iriga City15 Carnation St., DRJVillage, San Nicolas, I.C .Until Dec. 31, 2012 Roll No. 0001 P.T.R. No. 0002, 12/31/2007, Manila. IBP No. 0003, 12/31/2007, Manila. MCLE Compliance No. 1234 Serial No. of Commission: 07-11111 Doc. No. 9; Page No. 8; Book No. I; Series of 2012