Republic of the Philippines

REGIONAL TRIAL COURT

BRANCH 19
Justice Hall, Catarman, Northern Samar


JUAN DELA CRUZ,
Plaintiff, Civil Case No. 3579

-versus For: Ownership and
Recovery of Possession with
Damages

PEDRO SANTOS AND
JOSE CRUZ,
Defendants.
x------------------------------------------x


ANSWER


COMES NOW, defendant in the above-entitled case,
through counsel, unto this Honorable Court, most respectfully
states:

1. Answering the allegations of Paragraph 1, Defendant
Pedro Santos admit each and every allegation contained in said
Paragraph 1;

2. Answering the allegations of Paragraph 2 , Defendant
Pedro Santos allege that no information or belief sufficient to allow
to answer and so deny each and every allegation contained in said
Paragraph 2;

3. Answering the allegations of Paragraph 3 , Defendants
Pedro Santos allege that no information or belief sufficient to allow
to answer and so deny each and every allegation contained in said
Paragraph 3;

4. Answering the allegations in paragraph 4, Defendant Pedro
Santos specifically and categorically deny the allegation by plaintiff
in Paragraph 4;

5. That the Katibayan ng Orihinal na Titulo submitted as
annex A is a document issued by the Register of Deeds and form
part of evidence of ownership of the stated property in the said
certificate of title and the allegations in paragraph 5 which
Defendant Pedro Santos specifically deny has no basis since the
plaintiff did not submit any documents of ownership in their name
suggesting true ownership of the parcel of land subject of this case;

6. Answering the allegations in Paragraph 6 Defendant deny
such allegations;

7. Answering the allegations in Paragraph 7, Defendant
deny such allegations;

8. Answering the allegations of Paragraph 8, Defendant
Pedro Santos allege that no information or belief sufficient to allow
to answer and so deny each and every allegation contained in said
Paragraph 8;

AFFIRMATIVE DEFENSES

FIRST AFFIRMATIVE DEFENSE

The Complaint fails to state a cause of action against this
defendant upon which relief may be granted, and therefore, it
should be dismissed.

SECOND AFFIRMATIVE DEFENSE

The claim is barred by applicable statutes of limitation
and should be dismissed.

THIRD AFFIRMATIVE DEFENSE

If Plaintiff suffered any damages, which is specifically
denied, said damages were proximately caused or contributed
to by acts or omissions of persons other than this Defendant,
for which this Defendant has no liability.







WHEREFORE, Defendant prays that this Court dismiss the
Complaint of the Plaintiff herein, with costs and disbursements to
Defendant, together with such other relief the Court finds to be just
and proper.

July 4, 2014


ATTY. HERARDO G HERMOSILLA
COUNSEL FOR DEFENDANTS
Roll No 56789
IBP No 34567, PTR No 111213
MCLE Cert # IV-002-57 valid until 2015




VERIFICATION


I, Pedro Santos, am a defendant in the above-entitled action. I
have read the foregoing and know the contents thereof. The same is
true of my own knowledge, except as to those matters which are
therein alleged on information and belief, and as to those matters, I
believe it to be true.
I declare under penalty of perjury that the foregoing is true
and correct and that this declaration was executed at Catarman,
Northern Samar.

IN WITNESS WHEREOF, I have hereunto affixed my
signature this 4th day of July, 2014 in Catarman, Northern Samar
Philippines.




PEDRO SANTOS
Affiant
CTR No. 1314156
Issued at Catarman, Northern Samar
Issued on January 6, 2014



SUBSCRIBED AND SWORN before me this 4th day of July
2014, who exhibited to me his CTC No.1314156 issued on January
6, 2014 at Catarman, Northern Samar


Notary Public


ATTY. HERARDO G HERMOSILLA
Roll No 56789
IBP No 34567, PTR No 111213
MCLE Cert # IV-002-57 valid until 2015
My comm. Expires Dec. 31, 2014


Doc. No. .234...
Page No. .25..;
Book No. III..;
Series of 2014_.