Escolar Documentos
Profissional Documentos
Cultura Documentos
ANSWER
with SPECIAL and AFFIRMATIVE DEFENSES
and COUNTERCLAIM
COME NOW Defendants, through the Undersigned Counsel, unto this Most
Honourable Court most respectfully states that:
-IOn 17 May 2012, the above Complaint dated 23 April 2012 was received by
Defendant Susan Mijares.
payment be accepted by Plaintiff sometime November 2011 when the amount of Seven
Thousand Pesos, (Php. 7,000.00) was being paid by Defendant Susan Mijares, but the
same was unjustly refused, as admitted by Plaintiff.
-IXThe allegation under paragraph 14 of the Complaint in instantly raising the
amount of the rent from Php. 7,000.00 to Php. 10,000.00 is a manifestation of
Plaintiffs malicious motive and reason behind this sham action, and is unreasonable,
unjust and contrary to section 4 of R.A. 9653 which is herein quoted as follows:
...
SEC. 4. Limit on Increases in Rent. For a period of one (1) year from its
effectivity, no increase shall be imposed upon the rent of any residential unit covered
by this Act: Provided, that after such period until December 31, 2013, the rent of any
residential unit covered by this Act shall not be increased by more than seven (7%)
annually as long as the unit is occupied by the same lessee: (Italics Supplied)
b)
c)
DAVID B. AGONCILLO
Counsel for Defendant
Mailing Address:
Office Address:
Email address:
03 January 2012
atty_agoncillo4542@yahoo.com
Mobile No. 0919-279-7071
VERIFICATION AND
CERTIFICATION OF NONFORUM SHOPPING
I, Susan Mijares, is of legal age, Filipino, after having been duly sworn to
in accordance with law hereby depose and state that:
1. I am the Defendant in the above mentioned Case;
2. I have caused the preparation of the foregoing Answer with Special and
Affirmative Defenses with Counterclaim;
3. I have read all the contents and allegations therein, and that the same are
all true and correct to the best of my knowledge and based upon authentic
records;
4. I have not commenced any other action or proceeding before the
Honourable Supreme Court, the Honourable Court of Appeals or any
other Court, Tribunal or Agency involving the same parties or same
subject matter;
5. If there is any such action or proceeding which is either pending or may
have been terminated, I shall state the status thereof;
6. If I should learn later that a similar action or proceeding has been filed or
is pending before the Honourable Supreme Court, , the Honourable Court
of Appeals or any other Court, Tribunal or Agency, I will notify that fact
within five days from knowledge thereof.
Manila, __ May 2012.
________________
SUSAN MIJARES
Defendant-Affiant
NOTARY PUBLIC
Reg. No.___
Page No.___
Book No.___
Series of 2012
EXPLANATION
Copy of this pleading was served through registered mail upon Petitioners
Counsel, for lack of personnel to effect personal service thereof.
DAVID B. AGONCILLO
Copy Furnished:
Atty. RICO B. BOLONGAITA
Counsel for Plaintiffs
No 3264 Zapote Street, Makati City
______, 2012