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Republic of the Philippines SECOND JUDICIAL REGION REGIONAL TRIAL COURT Tuguegarao City

MILAGROS SEGUNTO, Plaintiff, CASENO.______ -versusMONEY ANDRES U. BARCENA, JR. Defendant X----------------------------------X REPLY


COMES NOW the plaintiff by the undersigned counsel and in reply to defendants answer respectfully alleges: The plaintiff denies any knowledge of the matters contained in Annex D and specifically denies the content of Annex E regarding the particulars mentioned therein, the truth of the matter is that the plaintiff issued such receipt for payment of an obligation, other than the obligation subject matter of the case. As to the counterclaim, plaintiff has no knowledge or information sufficient to form a belief as to the truth of the allegation in said counterclaim regarding damages and attorneys fees and therefore denies the same. WHEREFORE, it is respectfully prayed that plaintiff secures judgment on his complaint and that the counterclaim be denied. Tuguegarao City. 23 November 2012. ATTY. RICHARD L. SUYU Counsel for the Plaintiff 2nd Floor Laggui Bldg., Caritan Centro, Tuguegarao City MCLE Compliance No. III IBP No. 111508 MILAGROS B. SEGUNTO, of legal age, a resident of #3 Balzain Highway, Tuguegarao City, after having been duly sworn to, depose and say, that she is the plaintiff in the above-entitled case; and that she has read the allegation in the above reply and answer to counterclaim, and the allegations contained in the same are true to the best of her knowledge. MILAGROS B. SEGUNTO SUBSCRIBED AND SWORN to before me this 23rd day of November 2012, affiant exhibiting to me her Community Tax Certificate CCI 2011 issued on January 5, 2012 at Tuguegaro City. ATTY. DENNIS C. SAQUING Notary Public My Commission expires on December 31, 2012 Not.Reg.No.002 Page 002; Book 01 Series of 2012

SEGUNTO ALUMINUM AND GLASS SUPPLIES VAT Reg. TIN-914 -9769600 #3 Balzain Highway, Tuguegarao City, Cagayan
OFFICIAL RECEIPT ISSUED TO: _______________________________________ ADDRESS:_________________________________________ QUANTITITY UNIT No. 20123 Date:______________ ARTICLES

Amount _______________ Payment Mode: Particulars: Received by:____________________________