PAGE 1/4 RIZAL v.

BONIFACIO

Republic of the Philippines

REGIONAL TRIAL COURT
Second Judicial Region
BRANCH 23
Roxas, Isabela

Rizal (PLAINTIFF) v. Bonifacio (DEFENDANT)

Civil Case No. 23-001-19(ISU)
x----------------------------------------------------------------------------------------x
ANSWER
DEFENDANT, through counsel, comes to this Honorable Court, respectfully stating:

1. I am the DEFENDANT in the case filed by PLAINTIFF in the COMPLAINT for

recovery of possession, injunction and damages;

2. I am of legal age, a Filipino, married and a resident of 123 Barangay Wawa, Barangay
Rizal (now Camaal), Quirino, Isabela;

3. I received summons and a copy of the COMPLAINT on February 19, 2019;

4. It is not PLAINTIFF but I who is the registered owner of the subject property. His
Transfer Certificate of Title (TCT) No. T-123456 is a later certificate. I am in possession
of and registered as owner in Original Certificate of Title (OCT) No. M-000019 issued by
the Land Registration Authority (LRA) to me on September 8, 1992;

5. I admit that I have not declared the property for real estate tax purposes and I do not
contest the subject property’s assessed value as alleged in the complaint;

6. PLAINTIFF’s story about a band of goons called “Katipuneros,” evicting him from his
property by force, is a mere figment of his imagination and this absolutely did not
happen. This is bolstered by the fact that, from 1994 to 2018, I stayed in Korea as an
overseas Filipino worker (OFW) and could not have been able to organize such a group
as PLAINTIFF has imagined and alleged in his complaint;

7. While it is true that the subject property is classified as agricultural property, it is not
factual that I cultivate the land and derive income from it. I have recently built a house
for me and my family on said land out of my earnings from my job in Korea;

8. PLAINTIFF has no right to income from the subject property because I am the registered
owner thereof;

9. No such “repeated demands” have been made by PLAINTIFF upon me, either in oral or
written form to vacate the property;

10. This Honorable Court should not issue a writ of preliminary injunction, considering that
PLAINTIFF has not shown any clear right to protect. The PLAINTIFF’s TCT which he
has presented to court is sham;

11. PLAINTIFF is not entitled to damages because there is no violation of his right and there
is no correlative duty on my part to give him possession and enjoyment of the piece of
land in question;

12. Instead of the PLAINTIFF being entitled to attorney’s fees in the amount of 50,000
pesos, it is I who should be granted the same because I was compelled to file an
ANSWER to his COMPLAINT which has no basis in fact and in law;
PAGE 2/4 RIZAL v. BONIFACIO

ATTACHMENT
13. Attached with this ANSWER and made an integral part hereof is TCT No. No. M-000019
to prove that I am the registered owner of the subject property;

PRAYER
14. Based on the foregoing premises, it is most respectfully prayed that:
a. PLAINTIFF’s prayers in his COMPLAINT be denied; and
b. PLAINTIFF be ordered to pay me the following:
i. 50,000 pesos as attorney’s fees because I was compelled to hire the
services of ATTY. MARK ANGELO S. DELA PEÑA (my lawyer) to file
this ANSWER;
ii. 1,000 pesos as actual damages for the transportation expenses I have
incurred in going to and from Cauayan City, Isabela to communicate with
my lawyer regarding this case;
iii. 50,000 pesos as moral damages for emotional burden and social
humiliation that this baseless suit has caused me. PLAINTIFF’s claims
have no justification in fact or in law and this shows that he is in bad faith
in lodging this complaint and clogging the dockets of this Honorable
Court; and
iv. Other reliefs and remedies that are just and equitable under the
circumstances of this case and allowed by law and Rules.

Counsel signs this ANSWER for and on behalf of

DEFENDANT this day, Feburary 1, 2019, in the City of
Cauayan, Isabela.

ATTY. MARK ANGELO S. DELA PEÑA

08 DR. D. QUIRINO STREET, DISTRICT III
Cauayan City, Isabela
xffxcxxlmxrkxngxlx@gmail.com
09661234567
Roll No. 123456; September 8, 2018
IBP Lifetime Member No. 987654; March 8, 2018
PTR No. 741852963; May 8, 2018
MCLE Compliance No. VI-963852741; March 20, 2018

VERIFICATION
I, ANDRES C. BONIFACIO, of legal age, Filipino, married and a resident of 123 Barangay
Wawa, Barangay Rizal (now Camaal), Quirino, Isabela, UNDER OATH, certify that the
contents of and allegations in this ANSWER have been read by me and I know that they are true
and correct based on my personal knowledge and based on authentic records.

I sign this VERIFICATION attached to this ANSWER

this day, February 1, 2019, in the City of Cauayan,
Isabela.

ANDRES C. BONIFICIO
Affiant-Defendant
All papers and process to my counsel
PAGIBIG ID No. 127318923712
SSS/UMID No. 1247839574554
PAGE 3/4 RIZAL v. BONIFACIO

This day, February 1, 2019, this DOCUMENT (ANSWER) has been SUBSCRIBED and
SWORN TO before me by affiant-defendant who has shown me competent proof of his identity
as stated above (under his name and signature). This person whose signature appears above is the
one who executed this instrument and he acknowledge to me that this is an act out of his free and
voluntary will.

This ANSWER has four (4) pages including the attached certificate of title.

I hereby seal this with my signature as NOTARY

PUBLIC.

ATTY. MARK ANGELO S. DELA PEÑA

08 DR. D. QUIRINO STREET, DISTRICT III
Cauayan City, Isabela
xffxcxxlmxrkxngxlx@gmail.com
09661234567
Roll No. 123456; September 8, 2018
IBP Lifetime Member No. 987654; March 8, 2018
PTR No. 741852963; May 8, 2018
MCLE Compliance No. VI-963852741; March 20, 2018

Doc. No. : ________;

Page No. : ________;
Book No. : ________;
Series of 20_______.
PAGE 4/4 RIZAL v. BONIFACIO