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    Answer To Complaint

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    Roel Palmaira
    This document is an answer and compulsory counterclaim filed by the defendant Tenten Falso in response to a complaint for unlawful detainer filed by the plaintiff Lando. In the answer, the defendant admits some allegations of the complaint, denies others for lack of knowledge, and denies the alleged amount of attorney's fees. In the counterclaim, the defendant seeks attorney's fees of 20,000 pesos plus 3,000 pesos per court appearance for having to hire a lawyer to defend against the "unfounded suit", and 100,000 pesos in moral damages for the mental anguish and public humiliation caused by the suit. The defendant prays that the complaint be dismissed and the counterclaim be granted, and

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    Answer To Complaint

    Uploaded by

    Roel Palmaira
    269 views4 pages
    This document is an answer and compulsory counterclaim filed by the defendant Tenten Falso in response to a complaint for unlawful detainer filed by the plaintiff Lando. In the answer, the defendant admits some allegations of the complaint, denies others for lack of knowledge, and denies the alleged amount of attorney's fees. In the counterclaim, the defendant seeks attorney's fees of 20,000 pesos plus 3,000 pesos per court appearance for having to hire a lawyer to defend against the "unfounded suit", and 100,000 pesos in moral damages for the mental anguish and public humiliation caused by the suit. The defendant prays that the complaint be dismissed and the counterclaim be granted, and

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    Answer to Complaint

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    This document is an answer and compulsory counterclaim filed by the defendant Tenten Falso in response to a complaint for unlawful detainer filed by the plaintiff Lando. In the answer, the defendant admits some allegations of the complaint, denies others for lack of knowledge, and denies the alleged amount of attorney's fees. In the counterclaim, the defendant seeks attorney's fees of 20,000 pesos plus 3,000 pesos per court appearance for having to hire a lawyer to defend against the "unfounded suit", and 100,000 pesos in moral damages for the mental anguish and public humiliation caused by the suit. The defendant prays that the complaint be dismissed and the counterclaim be granted, and

    Copyright:

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

    Answer To Complaint

    Uploaded by

    Roel Palmaira
    This document is an answer and compulsory counterclaim filed by the defendant Tenten Falso in response to a complaint for unlawful detainer filed by the plaintiff Lando. In the answer, the defendant admits some allegations of the complaint, denies others for lack of knowledge, and denies the alleged amount of attorney's fees. In the counterclaim, the defendant seeks attorney's fees of 20,000 pesos plus 3,000 pesos per court appearance for having to hire a lawyer to defend against the "unfounded suit", and 100,000 pesos in moral damages for the mental anguish and public humiliation caused by the suit. The defendant prays that the complaint be dismissed and the counterclaim be granted, and

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    REPUBLIC OF THE PHILIPPINES

    METROPOLITAN TRIAL COURT


    BRANCH 2
    Makati CITY
    Landlord Lando
    represented by Maria Lando and his Atty in Fact
    Plaintif
    Civil Case
    No. 1
    Unlawful
    Detainer
    -

    Versus

    Tenten Falso,
    Defendants
    x---------------------------------x

    The DEFENDANT xxx, by counsel, respectfully states:


    ANSWER
    1.

    Paragraphs 5 and 7 of the Complaint are admitted.

    2. Paragraphs 9 of the Complaint are denied for lack of


    knowledge or information sufficient to form a belief as to the
    veracity or falsity thereof, the allegations therein being matters
    known only to, and are within the control only, of the plaintiff.
    3. Paragraph 11 of the Complaint is denied for lack of
    knowledge and information sufficient to form a belief as to the
    veracity or falsity of the alleged amounts of attorneys fees
    agreed upon between the plaintiff and her lawyer.

    III.

    COMPULSORY COUNTERCLAIM

    4 .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;
    5. 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.
    PRAYER
    WHEREFORE, premises considered, it is respectfully prayed that
    the parties be given ample time to reach an amicable settlement
    before the MakatiCity Mediation Center; and that in case of a
    failure thereof, and after trial, the complaint be dismissed for lack
    of merit and the defendants compulsory counterclaim be
    granted, i.e.. attorneys fees of P20,000.00 plus moral damages of
    P100,000.00, plus costs of suit.
    The defendant respectfully prays for such and other reliefs
    as may be deemed just and equitable in the premises.
    Makati City, 2016.
    ABC LAW OFFICES
    Counsel for Defendant
    123 Makati CIty
    Philamlife Village, Las Pinas City 1740
    Don Aba
    VERIFICATION
    AND

    ANTI-FORUM SHOPPINFG CERTIFICATION


    I, TenTen Falso, of legal age, married, Filipino, and with
    postal address c/o 123, Makati City, under oath, depose:
    I am the defendant in the foregoing case; that I caused the
    preparation of the foregoing Answer; that I have read its contents;
    and that the same are true and correct of my own direct, personal
    knowledge.
    Further, pursuant to Rule 7 of the 1997 Rules of Civil
    Procedure and existing Supreme Court circulars, I hereby certify
    that I have not heretofore commenced any other action or
    proceeding involving the same issues in the Supreme Court, the
    Court of Appeals, or any other tribunal or agency; that to the best
    of my knowledge, no such action or proceeding is pending in the
    Supreme Court, the Court of Appeals, or any other tribunal or
    agency; and that if I should hereafter learn that other similar or
    related actions or proceedings has been filed or is pending before
    the Supreme Court, the Court of Appeals, or any other tribunal or
    agency, I undertake to report that fact within five (5) days
    therefrom to this court.

    MakatiCity, December 20
    2017.
    Tenten
    Falso
    Affiant/Defendant
    SSS
    Member ID
    No. 12356
    Issued on
    1995

    SUBSCRIBED and sworn to before me in xxx City on xxx


    2011, the affiant showing his SSS Member ID Card as stated
    above as competent proof of his identity.

    NOTARY PUBLIC
    Doc. No. 1234
    Page No. _54123
    Book No. 1234
    Series of 2011
    Cc

    Atty. Don Aba


    Counsel for Plaintiff
    Makati City
    Metro Manila

    EXPLANATION
    A copy of this pleading is served via registered mail,
    instead of via personal service, on the adverse counsel due to the
    distance of his law office address and the lack of field staff of
    undersigned counsel at this time.

    Don Aba

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