Republic of the Philippines

National Capital Judicial Region

REGIONAL TRIAL COURT
Branch 123, Quezon City

BECKY N. POE,
Plaintiff,
Civil Case No. 20‐15435
For: Sum of Money
‐ versus ‐

MA. MERCEDES GO,

Defendant.
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ANSWER
(With COUNTERCLAIM)

DEFENDANT, through counsel, by way of answer to

plaintiff’s complaint, respectfully states that:

Admissions/Denials

1. She admits the allegations in paragraph 1 and 2 of the

Complaint regarding her personal circumstances;

2. She is without knowledge or information to form a belief as

to the truth of the allegations in paragraphs 4, 5, and 6 of
the Complaint;

3. She specifically denies each and every material allegation in

paragraph 3 of the Complaint, since such allegations are
maliciously false and meant only to unjustly enrich Plaintiff
at Defendant’s expense. The truth is the principal
 obligation amounts to only Five Hundred Fifty Thousand
Pesos (P550,000.00), but due to unconscionable interests,
excessive penalties and other charges, Defendant was
deceived into signing a receipt that showed, as Defendant
much later on learned, the aggregate amount of
indebtedness to be One Million Seventy Thousand Pesos
(P1,070,000.00), inclusive of the unconscionable interests,
excessive penalties, and other charges;

Counterclaim

4. Defendant additionally submits that she is entitled to relief

arising from the filing of this malicious and baseless suit,
as follows:

Moral Damages amounting to Fifty Thousand Pesos

(P50,000.00) because her name and reputation were
besmirched by this malicious and baseless suit.

Despite full payment by Defendant of the principal

obligation, Plaintiff has instituted the instant malicious suit
which compelled Defendant to engage the services of
counsel, in order to protect Defendant’s interests, for an
agreed professional fee of P150,000.00, plus an appearance
fee of P4,000.00 per hearing.

Defendant also incurred other litigation expenses in the

sum of P 50,000.00. For all of said fees and litigation
expenses, Plaintiff should be adjudged liable to Defendant.

WHEREFORE, Defendant respectfully prays that

judgment be rendered in her favor by dismissing the
Complaint and granting defendant's counterclaim by
awarding defendant: (a) Fifty Thousand Pesos (P50,000.00)
as Moral Damages, and (b) One Hundred Fifty Thousand
Pesos (P150,000.00) plus Four Thousand Pesos (P4,000.00)
for every hearing attended by Defendant’s counsel as
Attorney's Fees.

Other just and equitable reliefs are prayed for. Quezon City
February 5, 2020.

ATTY. STEPHANIE MANI

Counsel for Defendant
25 Tandang Sora., Quezon City
Attorney’s Roll No. 62562
IBP Lifetime No. 012126
PTR No. 97890/ January 15, 2020/ Quezon City
MCLE No. VI-0011089/ July 12, 2018

VERIFICATION AND CERTIFICATION

I, MA. MERCEDES GO, of legal age, after having been duly

sworn, depose and state that:

I am the Defendant in the foregoing Complaint for Sum of

Money.

I caused the preparation of the Answer (with Counterclaim),

which I have fully read and understood.

I hereby affirm that all factual allegations contained in said

Answer are true and correct of my own personal knowledge
and belief, as well as true and correct on the basis of
authentic documents and records in my possession.

I certify that I have not heretofore commenced any action or

filed any claim involving the same issues in any court,
tribunal, or quasi‐judicial agency.
If I should hereafter learn that any other similar action or
claim has been filed or is pending, I shall report that fact
within five (5) days from knowledge thereof to this
Honorable Court.

MA. MERCEDES GO

Copy furnished through personal service:

ATTY. BARBY T. GOW

Counsel for the Plaintiff
35 West Ave., Quezon City