DIAZ, Francis C.

July 17, 2018

2017400143 Legal Forms

Answer with Specific Denial

REPUBLIC OF THE PHILIPPINES

MUNICIPAL TRIAL COURT
LEGASPI CITY, ALBAY

POTTER, Harry CIVIL Case No: 1016

Plaintiff, For: Unlawful Detainer

-versus-

GRANGER, Hermione
Defendant,

x------------------------------------------x

ANSWER
(In Re: Complaint, Received on June, 2018)

NOW COMES the defendant in the above entitled case, and to this
Honorable Court most respectfully alleges:

1. Defendant admits the averment in paragraph 1, 2, and 3

of the complaint;

2. Defendant specifically denies the allegation in paragraph

5 of the complaint, the truth being that defendant has
been performing his obligation from February 1, 2015 up
to February 1, 2016.

3. Defendant has no knowledge or information to form a

belief as to the truth of the averment in paragraphs 5 of
the complaint;

THAT Defendant specifically denies under oath the genuiness and due
execution of the Contract of Lease, a copy of which is attached to
DIAZ, Francis C. July 17, 2018
2017400143 Legal Forms

Plaintiff’s complaint as “Annex A”, the truth being that his signature
thereon is forged and that he did not in fact sign the said instrument

WHEREFORE, it is respectfully prayed that the complaint be

dismissed.

Other equitable reliefs are likewise prayed for.

Legaspi City, July 17, 2018.

Atty. Francis C. Diaz

Counsel for the Defendant
#0143 Burgundy Tower,
Ayala Ave., Makati City

VERIFICATION and CERTIFICATION AGAINST FORUM SHOPPING

I, Hermione GRANGER, of legal age, single, Filipino, and with postal

address c/o Barangay Mainit, Legaspi City, under oath, depose:

1. I am the defendant in the foregoing case; that I caused the

preparation of the foregoing Answer;

2. I have read its contents; and

3. The same are true and correct of my own direct, personal

knowledge.

Further, pursuant to Rule 7 of the 1997 Rules of Civil Procedure and

existing Supreme Court circulars, I hereby certify that I have not
heretofore commenced any other action or proceeding involving the
same issues in the Supreme Court, the Court of Appeals, or any other
tribunal or agency; that to the best of my knowledge, no such action or
proceeding is pending in the Supreme Court, the Court of Appeals, or
any other tribunal or agency; and that if I should hereafter learn that
DIAZ, Francis C. July 17, 2018
2017400143 Legal Forms

other similar or related actions or proceedings has been filed or is

pending before the Supreme Court, the Court of Appeals, or any other
tribunal or agency, I undertake to report that fact within five (5) days
therefrom to this court.

Legaspi City, July 2018.

Hermione Granger
Defendant
SSS ID No: 109424

SUBSCRIBED and sworn to before me in Legaspi City on July 17,

2018, the defendant showing his SSS Member ID Card as stated
above as competent proof of his identity.

Atty. Ronald Weasley

Notary Public

Doc. No.: 08
Page No.: 08
Book No.: 08
Series of 2018
DIAZ, Francis C. July 17, 2018
2017400143 Legal Forms

Answer with Cross Claim

REPUBLIC OF THE PHILIPPINES

MUNICIPAL TRIAL COURT
LEGASPI CITY, ALBAY

POTTER, Harry CIVIL Case No: 1016

Plaintiff, For: Unlawful Detainer

-versus-

GRANGER, Hermione
Defendant,

x------------------------------------------x

ANSWER
(In Re: Complaint, Received on June, 2018)

NOW COMES the defendant in the above entitled case, and to this
Honorable Court most respectfully alleges:

1. Defendant admits the averment in paragraph 1, 2, and 3

of the complaint;

2. Defendant specifically denies the allegation in paragraph

5 of the complaint, the truth being that defendant has
been performing his obligation from February 1, 2015 up
to February 1, 2016.

3. Defendant has no knowledge or information to form a

belief as to the truth of the averment in paragraphs 5 of
the complaint;

By way of counterclaim, defendant alleges:

DIAZ, Francis C. July 17, 2018
2017400143 Legal Forms

1. That by virtue of this unwarranted and malicious act

initiated by the plaintiff, defendant was forced to engage
counsel in the sum of P10,000.00.

WHEREFORE, it is respectfully prayed that the complaint be dismissed

and defendant be awarded the amount of P5,000.00.

Other equitable reliefs are likewise prayed for.

Legaspi City, July 17, 2018.

Atty. Francis C. Diaz

Counsel for the Defendant
#0143 Burgundy Tower,
Ayala Ave., Makati City

VERIFICATION and CERTIFICATION AGAINST FORUM SHOPPING

I, Hermione GRANGER, of legal age, single, Filipino, and with postal

address c/o Barangay Mainit, Legaspi City, under oath, depose:

1. I am the defendant in the foregoing case; that I caused the

preparation of the foregoing Answer;

2. I have read its contents; and

3. The same are true and correct of my own direct, personal

knowledge.

Further, pursuant to Rule 7 of the 1997 Rules of Civil Procedure and

existing Supreme Court circulars, I hereby certify that I have not
heretofore commenced any other action or proceeding involving the
same issues in the Supreme Court, the Court of Appeals, or any other
tribunal or agency; that to the best of my knowledge, no such action or
proceeding is pending in the Supreme Court, the Court of Appeals, or
DIAZ, Francis C. July 17, 2018
2017400143 Legal Forms

any other tribunal or agency; and that if I should hereafter learn that
other similar or related actions or proceedings has been filed or is
pending before the Supreme Court, the Court of Appeals, or any other
tribunal or agency, I undertake to report that fact within five (5) days
therefrom to this court.

Legaspi City, July 2018.

Hermione Granger
Defendant
SSS ID No: 109424

SUBSCRIBED and sworn to before me in Legaspi City on July 17,

2018, the defendant showing his SSS Member ID Card as stated
above as competent proof of his identity.

Atty. Ronald Weasley

Notary Public

Doc. No.: 08
Page No.: 08
Book No.: 08
Series of 2018
DIAZ, Francis C. July 17, 2018
2017400143 Legal Forms

Answer with Affirmative and Negative Denial

REPUBLIC OF THE PHILIPPINES

MUNICIPAL TRIAL COURT
LEGASPI CITY, ALBAY

POTTER, Harry CIVIL Case No: 1016

Plaintiff, For: Unlawful Detainer

-versus-

GRANGER, Hermione
Defendant,

x------------------------------------------x

ANSWER
(In Re: Complaint, Received on June, 2018)

NOW COMES the defendant in the above entitled case, and to this
Honorable Court most respectfully alleges:

1. Defendant admits the averment in paragraph 1, 2, and 3

of the complaint;

2. Defendant specifically denies the allegation in paragraph

5 of the complaint, the truth being that defendant has
been performing his obligation from February 1, 2015 up
to February 1, 2016.

3. Defendant has no knowledge or information to form a

belief as to the truth of the averment in paragraphs 5 of
the complaint;

By way of affirmative and negative defenses, defendant avers:

DIAZ, Francis C. July 17, 2018
2017400143 Legal Forms

1. That the obligation has been paid;

2. That the defendant had lease said house and lot from
plaintiff and paid said monthly obligation;

3. That there is no cause of action against the defendant.

WHEREFORE, it is respectfully prayed that the complaint be

dismissed.

Other equitable reliefs are likewise prayed for.

Legaspi City, July 17, 2018.

Atty. Francis C. Diaz

Counsel for the Defendant
#0143 Burgundy Tower,
Ayala Ave., Makati City

VERIFICATION and CERTIFICATION AGAINST FORUM SHOPPING

I, Hermione GRANGER, of legal age, single, Filipino, and with postal

address c/o Barangay Mainit, Legaspi City, under oath, depose:

1. I am the defendant in the foregoing case; that I caused the

preparation of the foregoing Answer;

2. I have read its contents; and

3. The same are true and correct of my own direct, personal

knowledge.

Further, pursuant to Rule 7 of the 1997 Rules of Civil Procedure and

existing Supreme Court circulars, I hereby certify that I have not
DIAZ, Francis C. July 17, 2018
2017400143 Legal Forms

heretofore commenced any other action or proceeding involving the

same issues in the Supreme Court, the Court of Appeals, or any other
tribunal or agency; that to the best of my knowledge, no such action or
proceeding is pending in the Supreme Court, the Court of Appeals, or
any other tribunal or agency; and that if I should hereafter learn that
other similar or related actions or proceedings has been filed or is
pending before the Supreme Court, the Court of Appeals, or any other
tribunal or agency, I undertake to report that fact within five (5) days
therefrom to this court.

Legaspi City, July 2018.

Hermione Granger
Defendant
SSS ID No: 109424

SUBSCRIBED and sworn to before me in Legaspi City on July 17,

2018, the defendant showing his SSS Member ID Card as stated
above as competent proof of his identity.

Atty. Ronald Weasley

Notary Public

Doc. No.: 08
Page No.: 08
Book No.: 08
Series of 2018
DIAZ, Francis C. July 17, 2018
2017400143 Legal Forms