Answer to the Complaint Sample

REPUBLIC OF THE PHILIPPINES

METROPOLITAN TRIAL COURT
City of Manila
Branch 1
MICHAEL BADIRRI,
Plaintiff,

-versus- CIVIL CASE NO. 12345

EDIL FRANCISCO,
Defendant.
x--------------------------------------------x

ANSWER

COMES NOW, the defendant, through the undersigned counsel and unto this
Honorable Court, most respectfully avers:
1. That he ADMITS the contents of paragraph 2 only insofar as his personal
circumstances are concerned;
2. That he ADMITS his obligation of paying the monthly installments cited in
paragraph 3 of the complaint, but DENY the rest of the allegations therein as
said defendant’s obligation to plaintiff is not for the exercise of a right to
repurchase but for the amortization of a loan that he acquired from
the plaintiff at an interest of 12% per annum;
3. That defendant is without knowledge or information sufficient to form a
belief as to the veracity of the averments in paragraph 4 of the complaint;
4. That defendant does not, at the moment, have all the records of payments
he made to plaintiff, so that he also does not have information sufficient to form
a belief as the truth of the allegations in paragraph 5 of the complaint and,
therefore, DENY them.
WHEREFORE, the defendant respectfully prays that the complaint be
dismissed with costs against the plaintiff.

Other relief and remedies as may be deemed just and equitable under the
premises are likewise prayed for.

City of Manila, September 27, 2012.

GACUTAN AND SALAZAR LAW OFFICE

Counsel for the Defendant
Suite 258 The Tower
Malate, Manila
 By:
ARVIN GACUTAN
Roll No. 98765
IBP No, 12345/1-3-2012/Manila
PTR No. 34567/1-3-2012/Manila

Copy furnished:
ATTY. FRETTI LAUREL
Counsel for the Plaintiff
Unit 1234 Laurel Building
Sampaloc, Manila

EXPLANATION

Copy of the foregoing ANSWER was served to plaintiff’s counsel by

registered mail due to time and distance constraints and for lack of the
undersigned’s staff who can serve the same in person.

ARVIN GACUTAN

Posted 28th September 2012 by MRC

Complaint Sample

Republic of the Philippines

Municipal Trial Court

Branch 5

Baguio City
Mr. Uzumaki Naruto, plaintif Civil Case No. 2

Accompanied by his Attorney –in – fact, for:Unlawful Detainer

Atty. Poging Attorney

-versus-

Mr. Uchiha Sasuke, Defendant

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

COMPLAINT

COMES NOW, the plaintif together with the undersigned counsel to this most honorable court, MOST
RESPECTFULLY STATES THAT;

1. The Plaintiff is of legal age, married and a resident of Puguis, La Trinidad Benguet. The Defendant is
likewise of legal age, married and temporary residing at Petersville Subdivision, Baguio City.

2. The Plaintiff is the owner of the two-storey house unit located at the Petersville Subdivision, Baguio
City, and having the residential address of PV 123 as evidenced by pertinent documents like tax
declaration and deed of sale. ( EXHIBIT “A” )

3. The Defendant is the lessee of the house unit that is owned by the Plaintiff as evidenced by the
written contract of lease that both parties signed. (Exhibit “B”)
4. The Plaintiff and the Defendant came up with a written agreement of Lease on June 26, 2007,
which they both agreed upon and was duly signed by the two parties as shown in their contract of lease.
(Exhibit “B”)

5. Item No. 16 of the contract which the defendant signed expressly provides that he will only be
occupying the property for one (1) year, after which, he will vacate the house when that term expires.
(Exhibit “B”)

6. The contract also provides that the defendant should also take care of the property and its
premises” with the utmost diligence”.

7. On June 28, 2008, the plaintiff, after returning from Japan, was surprised to discover that the
defendant did not vacate the property as he expected. Worse, he installed a “sari-sari store” in the
original building structure of the house unit.

8. The plaintiff confronted the defendant about it but the defendant claimed that it was a “DEED OF
SALE” which they signed and not a “CONTRACT OF LEASE” and therefore, the defendant is the new
owner of the house unit.

9. On August 20, 2008, after continuous demands, the defendant constantly refuses to vacate the
house unit and even invited relatives to stay with him.

10. The defendant willfully and maliciously violated the agreement which they mutually agreed upon,
and which the defendant signed.

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of this Honorable Court that judgement
be rendered in favor of the plaintiff and that after judgement;

a. The defendant shall vacate the house unit owned by the plaintiff.

b. The defendant shall be ordered to pay P 120, 000 for the Attorney’s Fees.

Such other reliefs and remedies under the premises are likewise prayed for.
Baguio City, Philippines, this 28th day of September 2008.

Poging Attorney

Counsel for the Plaintif

PTR No. 18909595:1-04-07:B.C.

IBP No, 693095:1-04-07:B.C.

Roll No. 42481:5-10-97: Manila

Rm. 4 2/F Baguio Boating Center

180 Burnham Lake, Baguio City

VERIFICATION AND CERTIFICATION

I, Mr. Uzumaki Naruto, of Legal age, married, Filipino Citizen and a resident of Puguis, La Trinidad
Benguet, after being sworn according to law, hereby depose and state that;

1. I am a plaintiff in the above-stated case;

2. I caused the preparation of the foregoing complaint;

3. I have read the contents thereof and the facts stated therein are true and correct of my personal
knowledge and/or on the basis of copies of documents and records in my possession;

4. I have not commenced any other action or proceeding involving the same issues in the Supreme
Court, the Court of Appeals, or any other tribunal or agency;
5. To the best of my knowledge and belief, no such action or proceeding is pending in the Supreme
Court, the Court of Appeals, or any other tribunal or agency;

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

Uzumaki Naruto

Complainant

In witness thereof, I, Mr. Poging Attorney, counsel of the plaintiff, have herunto set my hand this 29 th of
September at Baguio City.

Poging Attorney

Counsel for the Plaintif

PTR No. 18909595:1-04-07:B.C.

IBP No, 693095:1-04-07:B.C.

Roll No. 42481:5-10-97: Manila

Rm. 4 2/F Baguio Boating Center

180 Burnham Lake, Baguio City