[Court]

[Region]
[COURT]
[City], [Branch No.]
[NAME]__________,
Plaintiff,
Civil Case No. ___________
For: Ejectment

- versus [NAME]__________,
Defendant.
x ----------------------------------- x
ANSWER
(With COUNTERCLAIM)
DEFENDANT, by counsel, respectfully states that:
Admissions/Denials

1. He admits the contents of paragraph 1 only insofar as his personal circumstances but specifically
denies the contents insofar as plaintiffs personal circumstances for the reason stated in the Affirmative
Defenses below.
2. He admits the contents of paragraph 2 only where it states that a Contract of Lease was entered into
but specifically denies that the Contract reflects the true intent of the parties as explained in the
Affirmative Defenses below.
3. He admits the contents of paragraph 3 only as to the fact that demand to vacate was made but
specifically denies its contents as to the truth of the reasons for the letter for lack of knowledge
sufficient to form a reasonable belief as to its truth or falseness.
4. He specifically denies the contents of paragraphs 4 to 6 for the reasons stated in the Affirmative
Defenses below.
Affirmative Defenses
5. Defendant reiterates, repleads and incorporates by reference all the foregoing insofar as they are
material and additionally submit that the Complaint should be dismissed because:
5.1. [STATE DEFENSES]
5.2 [STATE DEFENSES]
Counterclaim
6. Defendant reiterates, repleads and incorporates by reference all the foregoing insofar as they are
material and additionally submit that he is entitled to relief arising from the filing of this malicious and
baseless suit, as follows:
6.1. Moral Damages amounting to [AMOUNT IN PESOS IN BOTH LETTERS AND FIGURES] because [STATE
REASONS FPR THE CLAIM] ____________________.
6.2. Attorneys Fees amounting to *STATE AMOUNT IN PESOS IN BOTH LETTERS AND FIGURES+
_________________ because he was compelled to secure services of counsel to vindicate his legal
rights.

WHEREFORE, Defendant respectfully prays that judgment be rendered in his favor by dismissing the
Complaint and granting defendants counterclaim by awarding defendant: (a) *AMOUNT IN PESOS]
________________ as Moral Damages, and (b) *AMOUNT IN PESOS+ ____________ as Attorneys Fees.

Other just and equitable reliefs are also prayed for.

[CITY] ____________; [DATE] __________.

[SIGNATURE]
[NAME] _____________
Counsel for Plaintiff
[ADDRESS] ______________________

VERIFICATION & CERTIFICATION AGAINST FORUM SHOPPING

I, [NAME] ___________, of legal age, do hereby state that: I am the defendant in the case filed by
*PLAINTIFFS NAME+ _______________ for *TYPE OF CASE FILED+ ____________; in response, I have
caused the preparation of this Answer with Counterclaim; I have read its contents and affirm that they
are true and correct to the best of my own personal knowledge; I specifically deny the genuineness and
due execution as well as the binding effect of the actionable documents pleaded by plaintiiff; I hereby
certify that there is no other case commenced or pending before any court involving the same parties
and the same issue and that, should I learn of such a case, I shall notify the court within five (5) days
from my notice.
IN WITNESS WHEREOF, I have signed this instrument on [DATE] _________.
[SIGNATURE]
[NAME] ______________

SUBSCRIBED AND SWORN TO before me in the City of _______________ on this day of [MONTH AND
YEAR]_________________, affiant exhibiting before me his Government Issued ID no.
_______________ issued on [DATE}__________________ at [PLACE OF
ISSUANCE]_____________________.

[SIGNATURE]
[NAME]_______
Notary Public
Until [DATE]__________________
PTR No. [NUMBER] ____________
Issued at [PLACE]______________
On [DATE] ___________________
Doc. No.
Page No.
Book No.
Series of [YEAR] ___________.
Copy furnished through personal service:
[NAME OF COUNSEL] __________________
Counsel for the Plaintiff

[FIRM NAME] _______________

[ADDRESS] ________________

[USE THE FOLLOWING IF SERVICE IS NOT MADE PERSONALLY]

Copy furnished through registered mail:
[NAME OF COUNSEL] __________________
Counsel for the Plaintiff
[FIRM NAME] _______________
[ADDRESS] ________________
Registry Receipt No. ________
Post Office ________________
Date _____________________
EXPLANATION
The foregoing [DESIGNATION OF PLEADING, MOTION, ETC] _______________and its attachment were
served on [NAME OF COUNSEL] ________________ by registered mail instead of personal service as
counsel for petitioner [STATE REASON] ___________________.

[SIGNATURE]
[NAME] _________________

Republic of the Philippines)

City of _______________) s.s.
AFFIDAVIT
I, [NAME] ____________ , a messenger of [NAME OF COUNSEL FOR DEFENDANT], with office address at
[ADDRESS] __________________, after being duly sworn, deposes and states:
That on [DATE] ______________________, I served a copy of the following pleadings/papers by
registered mail in accordance with Section 10, Rule 13 of the Rules of Court:
Nature of Pleading/Paper
[STATE PLEADING/PAPER SENT]
________________________
in Case No. [CASE NUMBER] _________________ entitled [TITLE OF CASE] ____________________ by
depositing a copy in the post office in a sealed envelope, plainly addressed to [NAME OF
PARTY/ATTORNEY] _______________ at _______________ with postage fully paid, as evidenced by
Registry Receipt No. _____________________ attached and with instructions to the post master to
return the mail to sender after ten (10) days if undelivered.
TO THE TRUTH OF THE FOREGOING, I have signed this Affidavit on [DATE] ________________, in the
City of [CITY] _____________, Philippines.
[SIGNATURE]
[NAME] __________
Affiant

SUBSCRIBED AND SWORN TO before me in the City of _______________ on this day of [MONTH AND
YEAR]_________________, affiant exhibiting before me his Government Issued ID no.

_______________ issued on [DATE}__________________ at [PLACE OF

ISSUANCE]_____________________.

[SIGNATURE]
[NAME]_______
Notary Public
Until [DATE]__________________
PTR No. [NUMBER] ____________
Issued at [PLACE]______________
On [DATE] ___________________
Doc. No.
Page No.
Book No.
Series of [YEAR] ___________.