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Republic of the Philippines

REGIONAL TRIAL COURT


9th Judicial Region
Branch 16
Zamboanga City
SAM SUNG,
Plaintiff,

CIVIL CASE NO. __03__


FOR:SPECIFIC PERFORMANCE
WITH DAMAGES

-versusGAL AXY,
Defendant.
X----------------------------------X

ANSWER TO COMPULSORY COUNTERCLAIM


COMES NOW, the Plaintiff Sam Sung, through the undersigned
counsel, unto this Honorable Court, in the above-entitled case, most
respectfully allege:
1.
Averments of the Defendant in Paragraphs 13 and 14 of the
Answer are specifically denied for being mere conclusions of facts,
disputable in proper proceedings;
2.
Averment of the Defendant in Paragraph 15 is specifically
denied since entitlement to such award for the alleged damage is still
subject to the final determination of this case.

PRAYER
WHEREFORE, premises considered, Answering Plaintiff pray
unto this Honorable Court to render judgment, as follows:
1. To proceed in hearing the case until its final determination;
2.

To grant the reliefs originally prayed for in the initial Complaint.


Other reliefs as may be just and equitable in the premises are
likewise prayed for.
Zamboanga City, Philippines
SPECIFIC PERFORMANCE
CIVIL CASE NO. 03

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Atty. Fez Buok


Counsel for Plaintiff
PTR OR No. XXXXXXXXXXXXX
IBP OR No. XXXXXXXXXXXXX
Roll No. XXXXX

--- oOo --VERIFICATION/CERTIFICATION


I, Sam Sung, of legal age, Single, Filipino, with postal address at
Zamboanga City, Philippines, after having been duly sworn to an oath in
accordance with law, do hereby depose and say:
1. That I am the plainitff in the above-entitled case;
2.

That I have caused the preparation and filing of the foregoing Answer with
Compulsory Counterclaim;

3.

That I have read the pleading and that the allegations therein are true and
correct of our own personal knowledge or based on authentic records;

4. That we further certify that there is no other case involving the same issues and
parties before the Supreme Court, the Court of Appeals or Administrative bodies
and other agencies of the government, exercising quasi-judicial functions, I shall
inform the Honorable Commission about the same, within (5) days from
knowledge thereof.
IN WITNESS WHEREOF, we have hereunto set our hands this ___th day
of ______ 20015, at Zamboanga City, Philippines.
_____________
Sam Sung
- Oath Republic of the Philippines)
City of Zamboanga. . . . . )S.S.
X - - - - - - - - - - - - X)
SUBSCRIBED AND SWORN TO before me this __th day of _____ 2015,
Affiant exhibited to me his PhilHealth Card No. 14-025185567-2 issed on
PhilHealth Main Office at Zamboanga City, Philippines.
Doc. No.: 09
Page No.: 13
Book No.:40
2016
Series of 2014

Atty. Fez Buok


Notary Public
Commission until December __,

Copy furnished:

SPECIFIC PERFORMANCE
CIVIL CASE NO. 03

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