REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

MUNICIPAL TRIAL COURT
PASAY CITY, BRANCH____

AAA,
Plaintiff,

-versus- Civil Case No. __________

For: Unlawful Detainer
BBB,
Defendant.
x-------------------------------------x

ANSWER
COMES NOW, the defendant by the undersigned counsel,
respectfully alleges that:

1. Defendant ADMITS that portion of paragraphs 2 and 3 of the

complaint regarding the names, residences, status of the parties,
ownership and the land area of the disputed land, but DENIES the
rest thereof, for lack of knowledge sufficient to form a belief as to
the truth thereof;

2. Defendant ADMITS the statements made in paragraph 4 of the

Complaint;

3. Defendant DENIES specifically and every material allegation made

in paragraphs 5, 6 and 7 of the complaint; and alleges that the
defendant did not receive any demand orally or by means of a
written demand through a letter;

4. And as AFFIRMATIVE DEFENSE, the Defendant alleges:

A. That defendant religiously paid rentals on the subject House

and Lot as evidenced by receipts beginning from November
2016 up to the present; (copies of the Receipts are hereto
attached as Annexes "1")

5. As COUNTERCLAIM against the plaintiff, the defendant alleges:

A. 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 P20,000.00 plus P3,000.00 per court appearance;

B. Similarly, the plaintiffs unfounded suit has caused the

defendant mental anguish and suffering and public
 humiliation and embarrassment, for which the defendant
claims moral damages of P100,000.00;

WHEREFORE, it is respectfully prayed that:

(a) Prayer for judgment in favor of the Defendant with

respect to plaintiffs complaint;
(b) Prayer for judgment in favor of Defendant with
respect to counterclaim; and
(c) For such other relief consistent with law and equity,
and for costs.

Pasay City, September 8, 2017

X and Y-Z Law Office

Counsel for Defendant
Unit 8, William Godino bldg.
Star Ave., Pasay City 1630
Mobile Number: 0905-888-6666
Tel. No. 765-4321
Email Address: xy-z@xy-zlaw.com.ph

By:

(Signed)
X
IBP Lifetime No. 14388
PTR No. 0001235 / Pasay City / 08 January 2017
MCLE Compliance No. V-0012388
Roll No. 58888

REPUBLIC OF THE PHILIPPINES)

MAKATI CITY ) S.S.

VERIFICATION AND
CERTIFICATION AGAINST FORUM SHOPPING

I, BBB, Filipino, of legal age, married, with residence address at 456

Menlo St., Pasay City, after having been sworn to in accordance with law,
hereby depose and state that:

1) I am the defendant in the above-entitled case;

2) I have executed the foregoing statements and caused the

preparation of this Answer;
 3) I have read the pleading and that allegations thereof are true and
correct of my own personal knowledge or based on authentic
records;

4) I have not theretofore commenced any action or filed any claim

involving the same issues in any court, tribunal or quasi-judicial
agency and, to the best of my knowledge, no such other action or
claim is pending therein;

5) If I should thereafter learn that the same or similar action or claim

has been field or is pending, I shall report that fact within five (5)
days therefrom to the court wherein my aforesaid complaint or
initiatory pleading has been filed;

6) I executed this Verification and Certification Against Forum Shopping

to attest to the truth of the foregoing facts and in compliance with
the Supreme Court Circular No. 04-94.

IN WITNESS WHEREOF, I have hereunto affixed my signature this

8 day of September 2017 at the City of Pasay, Philippines.
th

(Signed)
BBB
Affiant

SUBSCRIBED AND SWORN TO before me on the aforementioned

date and place, affiant exhibiting to me his Driver's License No. 88888
issued by the Land Transportation Office on August 8, 2017, with validity
until August 8, 2022.

NOTARY PUBLIC

Doc. No.
Page No.
Book No.
Series of 2017