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    Reply To Complaint

    Uploaded by

    Wella Jane
    This document is a reply affidavit submitted on behalf of Primary Structures Construction Corporation in response to a counter-affidavit filed by Arturo Choi in an unlawful detainer case. It argues that Choi willingly entered into an agreement to use the property and made admissions of using the property. It also notes that Choi deposited money with a mediation body as part of a settlement to turn over the property, but still retains possession, constituting a breach. The affidavit requests that Choi be held liable for unlawful detainer based on the facts, witnesses and evidence presented.

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    © All Rights Reserved
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    Reply To Complaint

    Uploaded by

    Wella Jane
    111 views4 pages
    This document is a reply affidavit submitted on behalf of Primary Structures Construction Corporation in response to a counter-affidavit filed by Arturo Choi in an unlawful detainer case. It argues that Choi willingly entered into an agreement to use the property and made admissions of using the property. It also notes that Choi deposited money with a mediation body as part of a settlement to turn over the property, but still retains possession, constituting a breach. The affidavit requests that Choi be held liable for unlawful detainer based on the facts, witnesses and evidence presented.

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    Reply to Complaint

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    This document is a reply affidavit submitted on behalf of Primary Structures Construction Corporation in response to a counter-affidavit filed by Arturo Choi in an unlawful detainer case. It argues that Choi willingly entered into an agreement to use the property and made admissions of using the property. It also notes that Choi deposited money with a mediation body as part of a settlement to turn over the property, but still retains possession, constituting a breach. The affidavit requests that Choi be held liable for unlawful detainer based on the facts, witnesses and evidence presented.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    111 views4 pages

    Reply To Complaint

    Uploaded by

    Wella Jane
    This document is a reply affidavit submitted on behalf of Primary Structures Construction Corporation in response to a counter-affidavit filed by Arturo Choi in an unlawful detainer case. It argues that Choi willingly entered into an agreement to use the property and made admissions of using the property. It also notes that Choi deposited money with a mediation body as part of a settlement to turn over the property, but still retains possession, constituting a breach. The affidavit requests that Choi be held liable for unlawful detainer based on the facts, witnesses and evidence presented.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 4

    REPUBLIC

    OF THE

    PHILIPPINES

    Municipal Trial Court


    BRANCH 6, CEBU CITY
    7TH JUDICIAL REGION

    PRIMARY STRUCTURES CONSTRUCTION


    CORPORATION,
    Plaintif,

    CIVIL CASE NO.


    ______________________
    -versusFOR: UNLAWFUL DETAINER
    ARTURO CHOI,
    WITH PRAYER FOR PRELIMINARY
    MANDATORY INJUNCTION AND
    and all persons claiming rights under him,
    DAMAGES
    Defendants.

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

    REPLY AFFIDAVIT
    (RE: 25 February 2015 Counter-Affidavit
    of Respondent Arturo Choi)
    COMES
    NOW,
    the
    COMPLAINANT,
    PRIMARY
    STRUCTURES CONSTRUCTION CORPORATION, represented
    by AMANDA ROSE TAN-ONG, Filipinos, of legal age, and
    residents of #65 R. Landon St., Cebu City, Philippines, unto
    this honorable trial court, most respectfully alleges, in Reply
    to the Counter-affidavit of Respondent, ARTURO CHOI, copy
    of which was actually received on 30 February 2014 through
    courier LBC, that:
    1.)
    Respondent Arturo Choi was not forced to enter
    into a Kasunduan
    and that there was previous
    admission from him that he and his family were the
    ones who have used or benefited the property, which
    admission gave the legal ground for the Complainant to
    demand payment of the same. In addition, if and when
    he was not at fault then, he should not allow himself to
    pay the amount, as evidenced by a previous rental
    receipt and a letter written by him, requesting for the
    extension of the grace period of his payments due;
    2.) As evidenced by a deposited amount in possession of
    the Lupon Tagapamayapa, in the amount of fifty
    thousand pesos (P50,000.00) instead of the original
    amount of twenty thousand pesos (P20,000.00)
    demanded by the Respondent himself, he still retains
    1

    possession of the disputed property, and his denial of


    such fact is tantamount to a breach of the settlement
    agreed upon - that such property be turned over upon
    payment of the Complainant of the agreed settlement.
    3.)
    Needless to state, the Respondent has knowledge
    that the property had been sold to herein Complainant,
    as evidenced by the proof of delivery of the demand
    letters to vacate from the PHLPOST after disregarding
    the extended grace period given by herein
    Complainant.
    AND SO, given and based on the above facts, most
    reputable witnesses, and overwhelming evidences duly
    presented, it is respectfully prayed of the Honorable Court
    that Respondent ARTURO CHOI be held liable for UNLAWFUL
    DETAINER.
    25 March 2014 at Cebu City, Philippines.

    AMANDA ROSE TAN-ONG


    Affiant for the Complainant Primary
    Structures Corp.

    SUBSCRIBED AND SWORN, to before me on the date


    and place first-above written, affiant declaring under oath
    that all the allegations in the foregoing Reply- Affidavit are
    all true and correct. I hereby certify that I have personally
    examined the affiant and I am satisfied that she voluntarily
    executed and understood all the contents hereof

    Doc. No. ______;


    Page No. ______;
    Book No. ______;
    Series of ______;

    ATTY. CLEMENTE I.
    BEAUTY
    NOTARY PUBLIC
    UNTIL SEP. 13, 2016
    ATTYS ROLL NO 87980
    IBP NO. 345654 JANUARY
    2013
    ISSUED AT CEBU CITY

    ATA-LABISIG-DIAMBRANG LAW OFFICE


    Unit 404, 4th Floor, The Gregorian Bldg.
    2178 Osmena Blvd, Cebu City
    Tel. No.: (02) 353 8269
    E-mail: info@atlabrang-lawoffice.net
    BY:
    ATTY. WELLA JANE D.ATA
    Counsel for the Plaintif
    Roll No. 62254
    IBP Lifetime No. 012243
    PTR No. 2526871; 01/07/14; Cebu
    MCLE Compliance No. N/A (signed roll 4/26/13)
    ATTY. HANSARD C. LABISIG
    Counsel for the Plaintif
    Roll No. 59212
    IBP Lifetime No. 012260
    PTR No. 2526872; 01/07/2014; Cebu
    MCLE Compliance No. IV-0019395; 29 April2013
    ATTY. JALAINI DIAMBRANG
    Counsel for the Plaintif
    Roll No. 675879
    IBP Lifetime No. 012260
    PTR No. 2526872; 01/07/2014; Cebu
    MCLE Compliance No. IV-0019395; 29 April2013
    Doc. No. : 30
    Page No.: 6
    Book
    : I
    Series of 2013

    Copy Furnished:
    ATTY. ALEJANDRINA BALBUENA
    Carollo, Mandantes, Balbuena Law Firm Suite 203, LandCo
    Bldg. , Bajada Street, Cebu City

    Explanation: A Copy of this document was served through


    registered mail due to lack of material time and personnel.

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