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REPUBLIC OF THE PHILIPPPINES

METROPOLITAN TRIAL COURT


NATIONAL CAPITAL JUDICIAL REGION
BRANCH 1, QUEZON CITY


ABC Corporation,
Plaintiff,

-versus- CIVIL CASE NO. 111111
For: UNLAWFUL DETAINER

Juan W. Dela Cruz,
Defendant.
x------------------------------------------x

ANSWER

COMES NOW DEFENDANT JUAN W. DELA CRUZ, assisted by the by public
attorneys office, unto this Honorable Court, by way of Answer to the Plaintiffs Complaint,
most respectfully avers that:

1. For lack of knowledge and information sufficient to form a belief as to the truth and
veracity of the Complainants residence, Paragraph 1 of the Complaint is specifically
denied;

2. Defendant admits Paragraph 2 of the Complaint being the personal circumstances of the
Defendant;

3. Defendant admits Paragraph 3 of the Complaint regarding the Defendants ownership of
the subject property;

4. Defendant admits Paragraph 4 of the Complaint;

5. Defendant admits Paragraph 5 of the Complaint regarding the DEMAND LETTER;

6. Defendant Admits paragraph 6 of the Complaint on the matter refusing to vacate the
property because the property is already paid by him in the amount of forty five
thousand pesos (P45,000) and with ten post dated checks to Raul B. Roxas the General
manager of ABC Corporation in virtue of the lease contract between abc corporation
and defendant affixed with the signature of Carolo Miguel the president of abc
corporation which was notarized (Copy hereto attached as Annex A);

7. For lack of knowledge and information sufficient to form a belief as to the truth and
veracity thereof, Paragraphs 7 of the Complaint is specifically denied;


8. Plaintiffs allegation that defendant has no authority to the said property is of no merit
for the reason that a there is a lease contract entered into between defendant and
plaintiff which will give rise to a valid title or ownership;


PRAYER


WHEREFORE, it is most respectfully prayed of this Honorable Court that after due
notice and hearing, judgment be rendered DISMISSING the instant case for utter lack of
merit.

Defendant prays for further relief which may be deemed just and equitable under the
premises.

Quezon City, September 9 ______, 2014.



JUAN W. DELA CRUZ





Assisted by:

ATTY. JOHN FERDINEL MANALOTO
Public Attorney II
Roll no. 51922
IBP NO. 7644446 09-08-14
Compliance No. II- 00333339 009/2/14
Public Attorneys Office
Department of Justice
Room 107, Hall of Justice Building
Diliman, Quezon City


VERIFICATION


I, JUAN W. DELA CRUZ, of legal age, Filipino, after having been duly sworn to in
accordance with law, depose and say:

1. That I am the DEFENDANT in the instant case;
2. That I have caused the preparation of the foregoing ANSWER TO THE
COMPLAINT;
3. That I have read all the allegations therein and that the same are true of my own
personal knowledge based on existing authentic documents.


JUAN W. DELA CRUZ
Affiant

REPUBLIC OF THE PHILIPPINES )
QUEZON CITY ) S.S.

SUBSCRIBED AND SWORN TO before me this ___________ day of September 2014,
affiant exhibited to me her drivers license No.1438700 issued on September 2 2014, at Quezon City,
Philippines.


Doc. No._______ ATTY. JOHN FERDINEL MANALOTO
Page No._______ PUBLIC ATTORNEY II
Book No._______ PURSUANT TO R.A. 9406
Series No. 2009


Copy furnished:


ATTY. KELVIN MENDOZA
No. 25 Matalino st.
Teacher village, Quezon



EXPLANATION

Due to lack of manpower in the office, counsel for the Complainants was furnished
a copy of this Answer by registered mail in lieu of personal service.


ATTY. JOHN FERDINEL MANALOTO

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