REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
Manila, Branch 1

CONRAD PASCUAL,
Plaintiff
- versus- Civil Case No. 1234
For: Collection of Sum of Money,
CHRISTOPHER PASCUAL, Attorneys Fees and Other Reliefs
Defendant.
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ANSWER

NOW COMES the defendant in the above entitled case, and to this
Honorable Court most respectfully alleges:

1. That defendant admits the averment in paragraph 1, 2, 3, 4 and 5 of

the complaint;

2. That defendant specifically denies the allegation in paragraph 6 of the

complaint, the truth being that the obligation has been paid already.

3. That defendant has no knowledge or information to form a belief as to

the truth of the averment in paragraphs 7 and 8 of the complaint.

By way of special and affirmative defenses, defendant avers:

1. That the obligation has been paid;

2. That the defendant had paid said obligation from plaintiff in the
presence of plaintiffs wife and defendants son last December 1,
2016.
3. That plaintiff was not able to surrender to defendant the copy of the
original promissory note on the alibi that the same has been lost and
cannot be found.

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By way of counterclaim, defendant alleges:

1. That by virtue of this unwarranted and malicious act indicated by the

plaintiff, defendant was forced to engage counsel in the sum of
P10,000.00.

WHEREFORE, it is respectfully prayed that the complaint be dismissed

and defendant be awarded the amount of P5,000.00

Other equitable reliefs are likewise prayed for.

City of Manila, March 1, 2017

Atty. Romela M. Eleria

Counsel for Plaintiff
#6751 Office Tower Ayala Avenue
17th floor Makati, Philippines.
PTR No. 1473621, 01-08-2017
IBP OR NO. 123041,01-08-2017
Roll No. 489023

REPUBLIC OF THE PHILIPPINES )

CITY OF MANILA ) S.S.
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VERIFICATION AND CERTIFICATE

I, CHRISTOPHER PASCUAL, of legal age, married, Filipino and a

resident of #222 Juan Luna St., Tondo, Manila, under oath depose and state
that:

1. I am the defendant in the above captioned case;

2. I have caused the preparation of the foregoing answer;

3. I certify that they are all true and correct of my personal knowledge or
based on authentic records.

In witness whereof, I have hereunto set my hands this 1st day of March
2017, City of Manila, Philippines

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 Chrstopher Pascual
Affiant

SUBSCRIBED AND SWORN TO before me this 1st day of March

2017, at City of Makati, Philippines, affiant exhibiting to me his PRC I.D.
License No. 12345 issued in City of Manila on 07 July 2015 and valid until
07 July 2018.
Atty. Romela M. Eleria
Counsel for Plaintiff
#6751 Office Tower Ayala Avenue
17th floor Makati, Philippines.
PTR No. 1473621, 01-08-2017
IBP OR NO. 123041,01-08-2017
Roll No. 489023