REPUBLIC OF THE PHILIPPINES

METROPOLITAN TRIAL COURT

City of Batangas
Branch 8

Mr. Marky Shelo,

Plaintiff,

-versus- CIVIL CASE No. 333

M. Rael Ramos,
Defendant.
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ANSWER WITH CROSS-CLAIM

COMES NOW, the defendant, through the undersigned counsel and unto this Honorable Court,
most respectfully avers:
1. That he ADMITS paragraph 2 of the complaint;
2. That he DENIES paragraph 3 of the complaint, the truth being that it was the defendant RAEL RAMOS
who applied for and exclusively benefited from the loan with the plaintiff, answering defendant acting
as mere co-signer in the promissory note to accommodate defendant RAEL RAMOS and to guarantee
the loan;
3. That he lacks knowledge or information sufficient to form a belief as to the truth of the allegations
contained in paragraphs 3, 4, and 5 of the complaint and therefore, specifically DENIES the same;

SPECIAL/AFFIRMATIVE DEFENSES

4. That without the knowledge and consent of answering defendant, the principal condition of the
loan was changed and the term of payment thereof was unreasonably extended by the plaintiff, to the
prejudice of answering defendant;

5. That there was undue delay on the part of the plaintiff in enforcing the payment of the obligation,
and the loan could have been paid immediately at maturity had there been prompt and timely
notification to answering defendant of the non-payment of the loan by defendant RAEL RAMOS;

CROSS-CLAIM AGAINST HIS CO-DEFENDANT

6. That defendant RAEL RAMOS should reimburse answering defendant on any and whatever
amount the latter may be held answerable or which he may be ordered or suffered to pay under and
by virtue of the present action in favor of the plaintiff, answering defendant not having benefited
whatsoever from the loan which defendant RAEL RAMOS obtained from the plaintiff;

7. That defendant RAEL RAMOS should pay plaintiff directly and fully on the amounts claimed by
the latter in its complain he having benefited directly and exclusively from the transaction alleged in
the complaint;

WHEREFORE, premises considered, answering defendant respectfully prays to the Honorable

Court to render judgment as follows:
1. By dismissing the complaint against answering defendant;
2. By ordering defendant RAEL RAMOS to pay directly and fully to the plaintiff the amounts claimed by
the latter in the complaint;
3. By ordering defendant RAEL RAMOS to pay answering defendant for any and whatever amounts the
latter may be held liable to or be ordered or suffered to pay plaintiff under and by virtue of the plaintiff’s
claim in the present action.
Answering defendant prays such other relief and remedies as may be deemed just and
equitable under the premises.

City of Manila, June 25, 2018.

ATTY. Patrick Relox

Counsel for the Defendant Rael Ramos
Suite 888 Thor Tower
Lipa, Batangas

By:
Kratos Zeus
Roll No. 777
IBP No. 7777/1-18-2018
PTR. No. 777777/1-18-2018

VERIFICATION / CERTIFICATION OF NON-FORUM SHOPPING

Republic of the Philippines )

City of Batanhas ) S.S.

I, RAEL RAMOS, of legal age, Filipino citizen, single and resident of 666 San Matro St., Batangas,
after having duly sworn to in accordance with law, do hereby depose and say that:
1. I am the defendant in the above-entitled case;
2. That I have caused the preparation of the foregoing ANSWER and have read the allegations contained
therein;
3. The allegations in said answer are true and correct of my own knowledge and based on authentic
records;
4. I hereby certify that I have not commenced any other action or proceeding 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 a similar action or proceeding has been filed or is pending, I hereby
undertake to report that fact within five (5) days therefrom to the court or agency where the original
pleading and sworn certification contemplated herein have been filed;
6. I executed this verification/certification to attest to the truth of the foregoing facts and to comply with
the provisions of Adm. Circular No. 04-94 of the Honorable Supreme Court.

IN WITNESS WHEREOF, I have hereunto affixed my signature this 1st day of June 2018, in
the City of Batangas.

RAEL RAMOS

SUBSCRIBED AND SWORN TO before me this 1st day of June 2018, in the City of Batangas,
affiant exhibiting to me his SSS ID No. 123456 issued on June 5, 2018.

Doc. No. _______

Page No. _______
Book No. _______
Series of 2018.
Copy furnished:
ATTY. ALVIN RELOX
Counsel for the Plaintiff
Unit 888 Black Tower St.
Lipa, Batangas

Rael Ramos
Defendant
888 Sum St.
Batangas

EXPLANATION

Copy of the ANSWER was served by registered mail due to time and distance constraints and
for luck of the undersigned’s staff who can serve the same in person.

Kratos Zeus