Regional Trial Court

National Capital Judicial Region

METROPOLITAN TRIAL COURT
Branch 33, Quezon City

MAY REKLAMO,
Plaintiff,
Civil Case No. 1234
For: Ejectment
- VERSUS
WAGKA-NA Company,
Defendant.
x-------------------------------------------------------x

ANSWER
(WITH COUNTERCLAIM)
Defendant, by counsel, respectfully states that:
Admissions/ Denials
1.
He admits the contents of paragraph 1 only insofar as his personal circumstances
but specifically denies the contents insofar as plaintiffs personal circumstances for the reason
stated in the Affirmative Defenses below.
2.
He admits the contents of paragraph 2 only where it states that a contract of Lease
was entered into but specifically denies that the Contract reflects the true intent of the parties as
explained in the Affirmative Defenses below.
3.
He admits the contents of paragraph 3 only as to the fact that demand to vacate
was made but specifically denies its contents as to the truth of the reasons for the letter for lack
of knowledge sufficient to form a reasonable belief as to its truth or falseness.
4.
He specifically denies the contents of paragraphs 4 to 6 for the reasons stated in
the Affirmative Defenses below.
Affirmative Defenses
5.
Defendant reiterates, repleads and incorporates by reference all the foregoing
insofar as they are material and additionally submit that the Complaint should be dismissed
because:
5.1.
Plaintiff has no capacity to sue as it is a foreign corporation doing business
in the Philippines without a license.

5.2.
The Complaint fails to state a cause of action as the Contract of Lease
was, before its expiration, superceded by a Deed of Absolute Sale whereby plaintiff sold
to defendant the parcel of land in question, a copy of which is attached to ANNEX 1.
Counterclaim
6. Defendant reiterates, repleads and incorporates by reference all the foregoing insofar as
they are material and additionally submit that he is entitled to relief arising from the filing of this
malicious and baseless suit as follows:
6.1.
Moral Damages amounting to One Million Pesos (PHP1,000,000.00)
because his name and reputation were besmirched by this malicious and baseless suit.
6.2.
Attorneys Fees amounting to One Hundred Thousand Pesos
(P100,000.00) because he was 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 defendants counterclaim by awarding defendant: (a) One
Million Pesos as Moral Damages, and (b) Fifty Thousand as Attorneys Fees.
Other just and equitable reliefs are prayed for.
Quezon City; 16 November 2014.

(Sgd.) FRANCES BUENDIA

Counsel for Defendant
32 Coronado St. Pasig City
VERIFICATION & CERTIFICATION AGAINST FORUM SHOPPING
I, MAY REKLAMO, of legal age, do hereby state that: I am the defendant in the case
filed by WAGKA NA Company for ejectment; in response, I have caused the preparation of this
Answer with Counterclaim; I have read its contents and affirm that they are true and correct to
the best of my own personal knowledge; I specifically deny the genuineness and the due
execution as well as the binding effect of the actionable document pleaded by the plaintiff, I
hereby certify that there is no other case commenced or pending before any court involving the
same parties and the same issue and that, should I learn of such a case, I shall notify the court
within five (5) days from my notice.
IN WITNESS WHEREOF, I have signed this instrument on 16 November 2014.
(Sgd.) MAY REKLAMO
Copy Furnished To:

Atty. Carlos Medalla

Counsel for the Defense
193 San Isidro St. Brgy Montalban, Muntinlupa.