REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

SIXTH JUDICIAL REGION
BACOLOD CITY, BRANCH IX
NENA ROSE Z. BUGRONG
Plaintiff
versus

CIVIL CASE NO. 12345566

FOR: Collection of a Sum of Money

ROSHAN LANES TAGALIBOD

Defendant
xx

REPLY
I, Nena Rose Bugrong, in my own behalf, respectfully submit
hereunder my reply to the Answer of the defendant Roshan Lanes
Tagalibod, to wit:
By way of Reply to Defendants Answer:
The Petitioner admits the content of Paragraph 1 of the
answer insofar as the contracting of a loan amounting to Fifty
Thousand Pesos (P50,000.00) and the existence of promissory
note for the payment of such loan.
That the Petitioner specifically denies the content of
Paragraph 2 that she had made a complete payment in the
amount of P50,000.00 evidenced by the receipt annexed herein.
Such receipt presented were obtained
fraudulently by the
defendant.
The content of paragraph 3 of the answer is likewise denied,
It is clear from the foregoing promissory note annexed herein that
in the event that the borrower fails to pay on the due date, 30 %
will accrue as an interest and another 30% will accrue as a
penalty which amounts to a total of 60% annually.
With respect to paragraph 4 of the answer the same is
likewise rejected, the defendant herself have received the
demand letters evidenced by a return copy, signed by her and
attached herein as annexedC.

With respect to the allegation of the defendant that the this

action constitutes as unjust enrichment, the same should be
rejected. Unjust enrichment is committed when a person is
unjustly enriched at the expense of another, in our case, were
simply asking for equity.
The rest of the allegations is denied for lack of information or
knowledge sufficient to form a reasonable belief thereof.
P R AYE R
WHEREFORE, in view of the foregoing, Defendants most
respectfully pray for the dismissal of the complaint and the award
of counterclaim to them. Other reliefs are likewise prayed for.

ATTY. CARLO FRANCES E. CABALLERO

Counsel for the plaintif
NOBC Bldg., Gatuslao St., Bacolod City
Attorneys Roll No. 098532
IBP No. 24525-01/03/15-Bacolod
PTR No. 53532- 01/03/15-Bacolod
MCLE Compliance No. IV-0012345 November 17, 2014