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1,
2,3,4,5,6,
and
of
the
complaint
are
ADMITTED;
3. Paragraph 8 of the complaint is denied for the following
reasons:
a. Indeed there is a notice that the lease contract was
about to expire, but the plaintiffs did not take into
account that in the lease contract between defendant
and the city of Baguio, the contract between the
parties shall only commence after the proposed
gasoline station starts its business operation which is 5
years after the lease contract was executed, a copy of
such lease contract is hereunto attached as ANNEX
A;
AFFIRMATIVE DEFENSES
ANNE CURTIS
Affiant
SUBSCRIBED AND SWORN to before me, this 5th day of
March, by ANNE CURTIS, who exhibited to me her Community Tax
Certificate No. 4459686 issued at Baguio city, Philippines.
JOHN LLYOD CRUZ
Doc. No. 445;
COMMISSION
IBP NO.
Series of 2016;
COPY FURNISHED:
ATTY. MARIA LOURDES SERENA
Counsel for Plaintiff
EXPLANATION OF MODE OF SERVICE
In accordance with Section 11, Rule 13 of the New Rules on the
Civil Procedure, copy of this PLEADING is served by registered
mail for lack of available personnel to undertake personal service
upon the afore-named parties.