Republic of the Philippines

Regional Trial Court

National Capital Judicial Region
Branch 1, Manila

CONRAD PASCUAL,
Plaintiff,

Civil Case No. ________________

- versus - For: Collection of Sum of Money,
Attorneys Fees and Other Reliefs

CHRISTOPHER PASCUAL,
Defendants.

x--------------------------------------------------x

ANSWER

DEFENDANT CHRISTOPHER PASCUAL, by undersigned counsel, unto this

Honorable Court most respectfully states that:

1. Paragraphs one (1) to three (3) of the Complaint are admitted;

2. Paragraph four (4) to eight (8) of the Complaint is denied insofar as it alleges that the
defendant owes the plaintiff a sum of money and fails to pay the same, the truth being those
alleged in the special and affirmative defenses part hereinbelow;

SPECIAL AND AFFIRMATIVE DEFENSES

1. On January 03, 2016, the Defendant and the Plaintiff did not see each other and there
was no promissory note that was executed because the former was having a vacation in Baguio
City as evidenced by the photocopy of entry/exit of vehicles monitoring sheet, attached herein,
marked as Annex “A”, and made an integral part hereto. Such monitoring sheet is issued by
the Gate Security Department of the Subdivision where the Defendant resides.

2. The Plaintiff never gave the defendant the alleged amount of One Million Pesos
(₱1,000,000.00); that Defendant did not sign the alleged promissory note; and that Defendant’s
signature is forged.

COMPULSARY COUNTERCLAIM

Answer
 1. 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 interests for a professional fee of Twenty-Thousand Pesos (₱20,000.00)
and Three Thousand Pesos (₱3,000.00) per court appearance;

2. Similarly, the plaintiff’s unfounded suit has caused the defendant mental anguish,
wounded feelings, sleepless nights, serious anxieties, and other similar sufferings for which the
defendant claims moral damages of One Hundred Thousand Pesos (₱100,000.00).

PRAYER

WHEREFORE, PREMISES CONSIDERED, it is respectfully prayed to this

Honorable Court the dismissal of the complaint for lack of merit with costs against the plaintiff;
and that the defendant’s compulsory counterclaim be granted, i.e., moral damages of One
Hundred Thousand Pesos (₱100,000.00), attorney’s fees of Twenty-Thousand Pesos
(₱20,000.00), and Three Thousand Pesos (₱3,000.00) per court appearance and costs of suit.

Other reliefs just and equitable under the premises are likewise prayed for.

Tondo, Manila. February 25, 2016.

FRANCIS P. BUCU & ASSOCIATES LAW OFFICE

Counsel for the Defendant
Taft Ave., City of Manila
By:

FRANCIS P. BUCU
Roll of Attorney No. 22222
PTR No. 222222; 01-02-14 / Manila
IBP Life Member Roll No. 222222/07-08-14/ Manila
MCLE Compliance No. III-222222 / 12-10-16

Answer
 VERIFICATION and CERTIFICATION OF NON-FORUM SHOPPING

I, CHRISTOPHER PASCUAL of legal age, Filipino, married, and a resident of 222

Juan Luna st., Tondo, Manila, after having been duly sworn to in accordance with law, hereby
depose and state that:

1. I am the defendant in the above-stated case;

2. I have caused the preparation and filing of the foregoing Answer and have read
the allegations therein, and that they are true and correct of my personal knowledge and belief
and based on authentic documents;

3. I have not commenced any other action or proceeding involving the same issues
before the Supreme Court, Court of Appeals or any other tribunal or agency and, to the best of
my knowledge, there is no such action or proceeding pending before any tribunal;

4. If I should learn that a similar action or proceeding has been filed or is pending
before the Supreme Court, Court of Appeals or any other tribunal or agency, I undertake to
report that fact within five (5) days therefrom to this Honorable Court

IN WITNESS WHEREOF, I have hereunto set my hand this February 25, 2016 in
City of Manila.

CHRISTOPHER PASCUAL
Affiant

SUBSCRIBED AND SWORN to before me this December 5, 2015 in Lipa City,

affiant exhibiting to me her driver’s license with No. L03-654321 issued on May 2014, as
competent proof of her identity.

FRANCIS P. BUCU
Notary Public
Valid Until December 31, 2017
Roll of Attorney No. 22222
PTR No. 222222; 01-02-14 / Manila
IBP Life Member Roll No. 222222/07-08-14/ Manila
MCLE Compliance No. III-222222 / 12-10-16

Doc. No.: 49
Page No.: 8
Book No.: II
Series of 2015

Answer