Republic of the Philippines

12th Judicial Region

REGIONAL TRIAL COURT
Branch 4
Iligan City

VANGIE G. UTANGAN
Plaintiff, Civil Case No. 2018-092414
For: Collection of Sum of
-versus- Money with Damages

MAYA PALA U. TANG

Defendant.
x-------------------------------------------------------x

ANSWER

COMES NOW, the Defendant by undersigned Counsel and in answer to

Plaintiff’s Complaint in the above-entitled case, respectfully allege:
1. Defendant admits the averment in paragraph(s) 1,2,3,4 and 7.

2. Defendant specifically deny the allegation paragraph 5 of the Complaint, the

truth being that, the Defendant with a temporary receipt signed by the Plaintiff,
said Plaintiff received not just FORTY FIVE THPUSAND PESOS (P45,000.00) as
partial payment but received as reflected in the temporary receipt the amount of
ONE HUNDRED FORTY FIVE THOUSAND PESOS (P145,000.00) as partial
payment.

3. Defendant has no knowledge or information to form a belief as to the truth

of the averment in paragraph 6 of the Complaint, as the payment for the remaining
obligation is not yet overdue up until November 14, 2018 as reflected in the
“KASABUTAN” made by and between the Plaintiff and the Defendant, hereto
attached as Annex “A”.

4. Defendant vehemently denies under oath paragraph 8, the truth being that,
the Defendant did not acted fraudulently and has no intention to evade her
obligation with the Plaintiff.

5. Any allegation not expressly and specifically admitted herein shall be

generally denied.

WHEREFORE, premises considered, it is respectfully prayed that the

parties be given ample time to reach an amicable settlement before the Mediation
Center, and that in case of a failure thereof, and after trial, the Complaint be

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dismissed for lack of merit and Defendant Compulsory Counterclaim be granted,
i.e., Attorney fees plus moral damages of P50, 000.00, plus cost of suit.
The Defendants respectfully pray for such and other reliefs as may be
deemed just and equitable in the premises.
Iligan City, 28 September 2018.

DELIMUD LAW FIRM

131 Panay Reklamo Avenue, Aguinaldo Building
1103 Iligan City

RACQUEL M. DELIMUD
PTR No. 8438426; 1/04/2007; Iligan City
IBP No. 568943; 1/04/2007; Iligan City Chapter
Roll of Attorneys No. 34328

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

VERIFICATION and CERTIFICATION

I, MAYA PALA U. TANG, of legal age, Filipino, and a resident of Purok

Ilang-Ilang, Barangay Villaverde, Iligan City, after having been duly sworn to in
accordance with law, do hereby depose and state;

1. That I am the Defendant in the above-entitled case;

2. That I have caused the preparation of said Answer thru my counsel;

3. That I hereby certify that I have read and understood all the denials and
admittance contained therein;

4. That the contents therein are true and correct to the best of my personal
knowledge and based on documents in my possession;

5. That I further certify that there is no other action pending between the
same parties for the same cause of action and subject matter before the Supreme
Court, the Court of Appeals, or any other court or tribunal, and we hereby warrant
that if one is filed, or is known to exists, we will forthwith inform or notify this
Honorable Court within five (5) days from notice thereof.

IN WITNESS WHEREOF, I have hereunto set my hand on this ___ day of

September, 2018 at Iligan City, Philippines.

MAYA PALA U. TANG

Affiant

SUBSCRIBE AND SWORN to before me on ____ day of _________, 2018,

affiant having exhibited to me his Community tax Certificate No. __________
Issued on ____________, Issued at ______________.

Doc No. ____ ATTY. CARLO Z. SUAREZ

Page No. ____ PTR No. 5431011 – 1/3/18 - Iligan City
IBP Lifetime No. 010393/Iligan City
Book No. ____
Chapter
Series of 2018. MCLE Compliance No. V-0006521
Roll of Attorneys No. 8

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