COUNTER-CLAIM

Defendant RPRP hereby reiterates, repleads and incorporates by reference all the foregoing
averments insofar as they are material.

4.1. In order to protect and defend itself against the unwarranted and baseless complaint filed
by the Complainant, Respondent had to retain the services of a legal counsel for whose legal
services, the Respondents has agreed to pay attorneys fees in the following amounts:

Retainer Fee -------- P11,500.00 per month for the duration of the case

Appearance Fee--------P5,000.00 per appearance of counsel before any court, tribunal or

agency, or meeting with clients, witnesses or others in relation to this case

All of these must be paid by the plaintiffs.

PRAYER

WHEREFORE, it is respectfully prayed that , after hearing, judgment must be rendered in favor of
Defendant RPRP and against Plaintiffs:

(a) Dismissing the instant Complaint for lack of cause of action and/or lack of merit

(b) Payment of the sum of P11,500.00 per month as retainer fee and P5,000.00 per
appearance as attorneys fees

(c) Other reliefs that are just and equitable are also prayed for.

Makati City for Ligao City. 18 February 2011.

ZULUETA, PUNO and FERRER LAW OFFICES

6th Floor Vernida 1 Condominium
120 Amorsolo St., Legazpi Village
Makati City
Tel. Nos.: (2)8128849; (2)8929994

By:

JOSE PONCHO R. DEL ROSARIO

Roll Number 51880
IBP No. 770563, 08 January 2009, PPLM
PTR No. 1570455, 09 January 2009, Makati City
MCLE Certificate of Compliance No. II-0005559
Copy Furnished:
ATTY. WILLIAM B. BALAYO
Counsel for Plaintiff
913 Riosa St.,
Tabaco, Albay
4511

ATTY. PETER S. VEGA II

Counsel for Defendant Asistio
Colon St., Bagumbayan,
Ligao City
 VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

I, Rafael P. Puno, of legal age, with addresses at Unit 2010 Prestige Tower, F. Ortigas Jr. Road,
Ortigas Center, Pasig City, respectively after having been sworn to in accordance with law, do hereby
depose and state that:

1. I as the duly authorized representative of the Defendant Corporation in the above-entitled case
as evidenced by the Secretary Certificate attached hereto as Annex A;
2. I have caused the preparation of the foregoing Answer;
3. I have read the foregoing complaint and hereby certify that all the allegations therein contained
are true and correct t the best of our personal knowledge and based on authentic records;
4. That I have not commenced any action or proceeding involving the same issue s in the Supreme
Court, the Court of Appeals or any other tribunal or agency. To the best of my knowledge, no
such action or proceeding is pending in the Supreme Court, the Court of Appeals or any other
tribunal or agency. If there be any such action or proceeding which is either pending or may
have been terminated, I will state the status of the same. If I should learn that a similar action or
proceeding is pending before the Supreme Court, the Court of Appeals or any other tribunal or
agency, I hereby undertake to notify and inform this Honorable Office within five (5) days from
such notice;

IN WITNESS THEREOF, we sign this Verification and Certification of Non-Forum Shopping this
day of February 2011, at Makati City.

RAFAEL P. PUNO
Affiant

SUBSCRIBED AND SWORN to before me this _________day of ______________, August 2008,

affiants exhibiting to me his with ID No. , issued at ____and expiring on______.

NOTARY PUBLIC
 EXPLANATION

The foregoing Answer is being seved only on Atty. William B. Balayo and Atty. Peter S. Vega II by
way of registered mail due to heavy workload and lack of available office personnel.

JOSE POCHOLO R. DEL ROSARIO