Republic of the Philippines

Municipal Trial Court

Santa Maria Bulacan
Rysailu I. Cachero,
Plaintiff
-versusCivil Case no.00022
Mary Ann G. De Guzman,
Defendant
x------------------------------ x

ANSWER

ANSWER COMES NOW, the Defendant Ms. De Guzman, for

himself alone and answering the allegations of the complaint of file
herein, affirms, denies, and alleges as follows:
1. The Defendant admits the contents of paragraph only insofar as his
personal circumstances, but specifically denies the contents insofar as
plaintiff personal circumstances for the reason stated in the affirmative
defenses below.
2. The defendant admits the contents of paragraph 2 each and every
allegation contained in said paragraph states that she borrowed
money from the plaintiff but specifically denies the other allegations
as explained in the affirmative defenses below.

3. The defendant allege that the contents of paragraph 4 and 5 with no

information or belief sufficient to allow and to answer and so

defendant denied each and every allegation contained in said

paragraphs by the reason of the affirmative defenses below.
AFFIRMATIVE DEFENSES
4. The defendant asserts that the plaintiff did not clearly state the amount
or issues in this case. Making it difficult for the defendant to respond.
The defendant request that the court grant leave to amend this answer
to allow additional defenses once additional information is discovered
that will allow any additional defenses to be known by the defendant.
5. The complaints has failed to state an essential element for one or
more cause of action, specifically to the total amount borrowed was
already paid by the defendant.

COUNTERCLAIM
1. Defendant incorporate all of the matters admitted and alleged above.
Defendant entitled to their reasonably moral damages amounting to
one hundred twenty thousand (120,000.00) because his reputation
were distain by this malicious and baseless suit.
2. Defendant are entitled to reasonably attorneys fees amounting fifty
thousand pesos (50,000.00) because she was compelled to secure
services of counsel to vindicate his legal rights.
WHEREFORE, having fully answered the complaint the
defendant prays that the judgment rendered in her favor by dismissing
the complaint and granting the defendant s counterclaim. The court
order such other and further relief for the defendant as this court
deems just and proper.

Republic of the Philippines

Municipal Trial Court
Santa Maria Bulacan

Rysailu I. Cachero,
Plaintiff

-versusCivil Case no. 00022

For: Sum of Money
Mary Anne G. De Guzman,
Defendant

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

COMPLAINT
The complaint of the Plaintiff, respectfully shows and alleges as
follows:
1. The plaintiff herein, Rysailu I. Cachero is a Filipino of legal age and a
resident of Santa Maria, Bulacan, the defendant Mary Ann De
Guzman is also a Filipino of a legal age and also a resident of Santa
Maria Bulacan.

2. The Defendant engaged in the Ka-Negosyo Loan. She borrowed

certain amounts from Ka-Negosyo loan which is owned by the
Plaintiff Ms. De Guzman. The Plaintiff and the Defendant discussed
her needs and specification for this loan.

3. On June 12, 2014, Plaintiff and Defendant entered into written

agreement. Defendant agreed to pay the sum of One Hundred
Thousand Pesos (100,000.00) on an installment basis monthly. On the
same day Plaintiff gave to Defendant a certified check in the sum of
One Hundred Thousand Pesos (100,000.00) which Defendant Cashed
it.
4. The Defendant failed to pay any amount to Plaintiff as no installment
payments has been made on or before December 22, 2014 as agreed.
Plaintiff made numerous phone calls and sent several texts to
Defendant about the contract, but no response.
5. By reason of the facts and circumstances stated above. Defendant has
breached the contract by reason of defendants unreasonable failure or
refusal to pay his due and demandable obligation. Plaintiff has been
damaged by Defendant the sum of One Hundred Thousand Pesos
(100,000.00).
PRAYER
WHEREFORE, Plaintiff demands judgment against Defendant in
the sum of One Hundred Thousand Pesos (100,00.00), plus the
interest from December 22,2014 with legal interest together with any
other relief the court finds to be just and proper.

Dated: January 25, 2015

Atty .Juaquin G. Enguillo
Counsel for Plaintiff
City of Malolos

VERIFICATION and CERTIFICATION AGAINST FORUM

SHOPPING

I, Juaquin G. Enguillo, of legal age, do hereby state that: I am

the legal counsel of Ms.Rysailu I. Cachero and such capacity, caused
this complaint to be prepared; I have read the foregoing complaint and
know the contents thereof. The same are true to my knowledge except
as to matters therein stated to be alleged on information and belief and
as to those matter, I believe them to be true. I learn of such a case. I
shall notify the court within 5 days from notice.
To my best of knowledge, information and belief formed after
an inquiry reasonable under the circumstances. I have signed this
instrument on 25 January 2015.
Atty. Juaquin G. Enguillo
Notary public
My commission expires dec 1, 2016