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LOVELITO S. LUMOGDA,
Plaintiff, CIVIL CASE NO. 6669-2
-versus- - for -
ANSWER
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6. Paragraph 10 of the complaint is specifically denied the
truth being stated in the affirmative and special defenses
hereunder;
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12. In relation to the above-mentioned statements, it is to
be noted also that defendant has in possession of the property
for such number of years (5 years to be exact) and has built
permanent residential structure and even introduced
improvements thereon before the plaintiff made demand letters
to the defendant which was only on March 22, 2017 and July 24,
2017, respectively;
COUNTERCLAIM
16. As averred above, plaintiff is in total bad faith in filing
this baseless suit. To set to the public as an example, the plaintiff
should pay the sum of One Hundred Thousand Pesos
(P100,000.00) as exemplary damages;
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2. On the COUNTERCLAIM, ordering plaintiff to pay to
defendant the following:
a) The sum of One Hundred Thousand Pesos
(P100,000.00) as exemplary damages;
RESPECTFULLY SUBMITTED.
EXPLANATION
Copy of this pleading was sent to the opposing counsel
through registered mail as personal service is impracticable.
Copy furnished:
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REPUBLIC OF THE PHILIPPINES)
CITY OF GENERAL SANTOS ) S.S.
x---------------------x
ILUMINADA GUSTILO
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Defendant
Doc. No _____;
Page No. ____;
Book No. ____;
Series of 2018.
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