Republic of the Philippines

REGIONAL TRIAL COURT

6TH Judicial Region
Iloilo City

BARBIE G. SUYO,
Plaintiff,
CIVIL CASE NO. 2018-1
-versus- FOR COLLECTION OF SUM
OF MONEY
JEREMIA PICCIOBELEN G. PACANA,
Defendant.

/------------------------------------------------/

ANSWER

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

Defendant admits the averment in paragraph 1, 2 and 3 of the complaint;

1. Defendant specifically denies the allegation in paragraph 4 of the

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

2. Defendant has no knowledge or information to form a belief as to the

truth of the averment in paragraphs 5,6 and 7 of the complaint;

By way of special and affirmative defenses, defendant avers:

1. That the obligation has been paid;

2. That the cause of action has prescribed.

By way of counterclaim, defendant alleges:

That by virtue of this unwarranted and malicious act initiated 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.

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Other equitable reliefs are likewise prayed for.

Iloilo City, Philippines, January 16, 2018

ATTY. ROBESPIERRE S. TERSOL

Counsel for the Defendant
TERSOL AND TERSOL LAW OFFICE
Roosevelt Street, Santa Barbara, Iloilo
Iloilo City 5002
Roll No. 928888
MCLE Compliance No.: III-0007418
PTR No 928888, May 25, 2017
IBP No. 778888 Lifetime Iloilo City

VERIFICATION AND CERTIFICATION

I, BELEN G. PACANA, of legal age, married, Filipino and a resident

of Quintin Salas, Jaro, Iloilo City, under oath depose and state that:

a) I am the defendant in the above captioned case; I have caused the

preparation of the foregoing answer;

b) I have read the allegations contained therein; and

c) 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 hand this 16th day of January
2018 at Iloilo City, Philippines.

BELEN G. PACANA

SUBCRIBED AND SWORN TO before me this 16th day of January

2018 in Iloilo City, Philippines, affiant exhibiting to me her PRC I.D. no.
123456 issued in Iloilo City on June 30, 2016 and valid until June 30, 2018.

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 ATTY. ROBESPIERRE S. TERSOL
Notary Republic
TERSOL AND TERSOL LAW OFFICE
Roosevelt Street, Santa Barbara, Iloilo
Iloilo City 5002
Roll No. 928888
MCLE Compliance No.: III-0007418
PTR No 928888, May 25, 2017
IBP No. 778888 Lifetime Iloilo City

Doc. No.
Page No.
Book No.
Series of 2018

Copy furnished:

ATTY.GENEVIEVE S. TERSOL
Counsel for the Plaintiff
TERSOL - TERSOL LAW OFFICE
Lopez Jaena Street, Jaro
Iloilo City 5000