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Republic of the Philippines

Municipal Trial Court


8
th
Judicial Region
Branch 19
Catarman, Northern Samar



Julius D. Fodra and Kristine Gallardo-Fodra, Civil Case No. 27643
Plaintiff, accompanied by their Attorney-in-fact, for: Damages, Loss
Atty. Joelyn Soldevilla-Biag earning capacity,
Moral Damages,
Attorneys Fees


-versus-




Gladys Marie Hechanova representing
Her son Rey Hechanova
Defendant

x-----------------------------------------------------x
ANSWER

DEFENDANT, by counsel, respectfully submits this answer in substantiation
on her plea to lower the amount for damages prayed for by the plaintiff, to wit:
1. Defendant Gladys Marie C. Hechanova, of legal age, single and a resident of
University of Eastern Philippines, Catarman Northern Samar.
2. Herein named defendant acts as representative of her son, Rey Hechanova, 17
years of age.
3. That sometime in in the morning of March 1, 2014, my son Rey Hechanova
allegedly slightly hit the couple, Julius and Kristine Gallardo-Fodra by his
motorcycle as they passed by our gate.
4. That on that fateful morning, my son Rey honked the horn of the motorcycle
before slowly driving out of our gate.
5. That it was not the intention of my son Rey Hechanova, to hit the passersby
considering that he honked the motorbikes horn before slowly driving out of
the gate, thus taking in consideration the presence or crossing of would-be
passers-by.
6. That the unfortunate accident happened not only due to my sons negligence
but as well as the couples sense of safety awareness as they should have been
aware of the motorbikes honks.
7. That the negligence of the plaintiffs in not noticing the motorbikes honks
negates the cause of action. Hence, there is no cause of action.

PRAYER

WHEREFORE, it is respectfully prayed for of this Honorable Court that
judgment be rendered in favor of the defendant and the dismissal of the case.
Defendant likewise prays for costs and for such other relief as this Honorable
Court may deem just and equitable in the premises.

IN WITNESS WHEREOF, I Atty. Mikhael S. Dagutdot, counsel of the
defendant, hereunto set my hand this 5
th
day of March in the year 2014 at Catarman,
Northern Samar, Philippines.


ATTY. MIKHAEL S. DAGUTDOT
COUNSEL
PTR No. 17689595:1-04-07:B.C.
IBP No. 692955:1-04-07:B.C.
Roll No. 08581:5-10-97

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