-versusFRANCISCO TORRES,
Defendant.
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ANSWER
DEFENDANT, by counsel, respectfully states that:
Admissions/ Denials
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Affirmative Defense
8. Defendant reiterates, repleads and incorporates all the forgoing in so far as they are
material and additionally submit that the Complaint should be dismissed because:
8.1. The Plaintiff has no personal knowledge of the circumstances at hand.
8.2. The Obligation had been paid for.
8.3. The suit was brought to harass the Defendant because he was able to beat the
Plaintiff at a Mahjong game thereby obtaining Two Hundred Thousand Pesos (Php
200,000.00) From Her.
Counter Claim
9. Defendant reiterates, repleads and incorporates all the forgoing in so far as they are
material and additionally submit that he is entitled to relief arising out of the filing of this
malicious and baseless suit, as follows:
9.1. Moral Damages amounting to One Hundred Thousand Pesos (Php 100,000.00)
because his name and reputation were besmirched by this malicious and baseless suit.
9.2. Attorneys Fees amounting to Fifty Thousand Pesos (Php 50,000.00) because he was
compelled to secure the services of a counsel to defend his legal rights.
WHEREFORE, Defendant respectfully prays for that judgment be rendered in his favor
by dismissing the Complaint and granting Defendants counterclaim by awarding: (a) One
Hundred Thousand Pesos as Moral Damages, and (b) Fifty Thousand Pesos as Attorneys Fees.
Other just and equitable reliefs are also prayed for.
City of Makati; 5 December 2014.
CATHERINE C. GACUTAN
Counsel for Defendant
Roll of Attorney No. 10118
IBP No. 67890/02-23-12/Makati
PTR 123456/12-08-11/Makati
24th flr., Sky Tower, Rockwell Drive, Rockwell Center, Makati City
Metro Manila
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