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REPUBLIC OF THE PHILIPPINES

METROPOLITAN TRIAL COURT


NATIONAL CAPITAL JUDICIAL REGION
BRANCH 25
QUEZON CITY

LEONORA JUAREZ,
Plaintiff,

- versus – CIVIL CASE No. QC-1234


FOR: Ejectment

FERDINAND MANES,
Defendant.
x--------------------------------------x

ANSWER
Defendant Ferdinand Manes, thru counsel and unto this
Honorable Court, respectfully states that:

ADMISSIONS AND DENIALS

1. Paragraph 1 of the Complaint is ADMITTED


relating to the personal circumstances of the plaintiff.

2. Paragraph 2 of the Complaint is DENIED for not


indicating the correct address of the defendant.

3. Paragraph 3 of the Complaint is DENIED for lack of


knowledge or information sufficient to form a belief as to the
veracity or falsity thereof.

4. Paragraphs 4, 5 and 6 are likewise DENIED for lack


of knowledge or information sufficient to form belief as to the
truth thereof.

NEGATIVE AND AFFIRMATIVE DEFENSES

Defendant repleads all the foregoing averments in


support of its special and affirmative defenses, and
additionally states, that:
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Answer
Juarez v Manes
Civil Case No. QC-1234

5. The defendant’s occupation of the subject property


is not by mere verbal agreement without expressed obligation
to pay but by a contract of lease executed between defendant
and the former owner. Said Contract of Lease is hereto
attached as Annex “1”.

6. The defendant did not incur unpaid rentals as


evidenced by receipts, marked as Annex “2”. The Lease
Contract for five (5) years has not yet expired.

7. The continuous possession by the defendant is not


illegal and unlawful because she has complied with the terms
and conditions specified in the Lease Contract executed
between the former owner and the defendant.

8. The former owner of the property did not inform the


defendant about the sale of the property.

9. The dispute was not referred to the Lupong


Tagapamayapa of Brgy. Kaligayahan, Novaliches, Quezon City
but only to Jordan Subdivision Homeowners Association. The
Minutes of the Meeting is hereto attached as Annex “3”.

COMPULSORY COUNTERCLAIM

10. By reason of the abuse of right committed by the


plaintiff and by reason of the instant precipitate and
unfounded suit, the defendant was constrained to hire the
services of a lawyer to defend his rights and interest for a
professional fee of Php50,000.00 plus Php3,000.00 per court
appearances.

11. Similarly, the plaintiff’s unfounded suit has caused


the defendant mental anguish and suffering and public
humiliation and embarrassment, for which the defendant
claims moral damages of Php100,000.00.

PRAYER

WHEREFORE, it is respectfully prayed that the parties


be given ample time to reach an amicable settlement and that
in case of failure thereof, and after trial, the complaint be
dismissed for lack of merit and the defendant’s compulsory
counterclaim be granted.
Page 3 of 4

Answer
Juarez v Manes
Civil Case No. QC-1234

Other reliefs just and equitable are likewise prayed for.

Quezon City for Quezon City, September 9, 2018.

JEFFREY P. REYES
Roll No. 34567 4/25/13
IBP No. 1066801 1/13/18
MCLE Compliance No. VI-0016704

Reyes Law Office


Mountain Heights Subdivision,
Caloocan City
Tel. No. 428-9144 to 45
Email:gaitojef@gmail.com

Copy furnished:

Atty. Luis Santos


Counsel for the Plaintiff
Santos-Angeles Law Office
5 Marytown Circle, Greenfields I
Kaligayahan, Novaliches, Quezon City

Leonora Juarez
Plaintiff
45 Marytown Circle, Greenfields I
Kaligayahan, Novaliches, Quezon City

EXPLANATION
(Pursuant to Section 11, Rule 13 of the 1997
Rules of Civil Procedure)

The foregoing Answer will be filed and served personally.

JEFFREY P. REYES
Page 4 of 4

Answer
Juarez v Manes
Civil Case No. QC-1234

VERIFICATION AND CERTIFICATION


OF NON-FORUM SHOPPING

I Ferdinand Manes, Filipino of legal age, with residence


address at 123 Duhat St., Jordan Subdivision, Sta. Monica,
Novaliches, Quezon City after having been duly sworn to in
accordance with law, do hereby deposes and states:

1.) I caused the preparation of the foregoing Answer;

2.) I have read and understood the contents thereof


and hereby certify that the same are true and correct to the
best of my personal knowledge and/or authentic records;

3.) I further certify that I have not theretofore


commenced any action involving the same issues and the
same parties in any court, or tribunal or quasi-judicial agency
and, to the best of my own knowledge, no such other action is
pending therein, and should I thereafter learn that the same or
similar action is pending before any courts or tribunal, I
undertake to report such fact within five (5) days therefrom to
the court wherein the said action has been filed.

IN WITNESS WHEREOF, I hereunto set my hand this 9th


day of September 2018.

FERDINAND MANES
Affiant

SUBSCRIBED AND SWORN to before me this ____ day of


_____ 2018 at Quezon City affiant being known to me and
appearing before me with his SSS e-card No. 6767788997 and
who signed said document in my presence and swore that he
understood the contents thereof and that the same was his
free and voluntary act and deed.

Doc. No. ____


Page No. ____
Book No. ____
Series of 2018.