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Republic of the Philippines

REGIONAL TRIAL COURT


Tuguegarao City
Second Judicial Region
Tuguegarao City, Cagayan
MARQUS DELANTADO
Plaintiff,
- versus

CIVIL CASE NO.___________


FOR: COLLECTION OF SUM OF MONEY

PATROCENIO ALILAM
AND ALFIANA ALILAM
Defendants

ANSWER
COMES NOW, the defendants by undersigned Counsel and in answer to plaintiffs
complaint in the above- entitled case, respectfully allege:
1. Defendants admit the averment in paragraph 1 and 2 of the complaint;
2. Defendants specifically deny the allegation in the paragraph 3 of the complaint, the
truth being that, Bimbo Arias and the defendants never seen and talked each other on
July 12, 2014, because the defendants were in Baguio City. As evidenced by the
photocopy of entry/exit of vehicles monitoring sheet issued by the Gate Security
Department of the Subdivision where the defendants reside. (Annex A)
3. Defendants specifically deny the allegation in the paragraph 4 of the complaint, the

truth being that, the plaintiff never gave the defendants the alleged amount of Three
Hundred Fifty Thousand Pesos (350,000.00) and that their signatures are forged and
that they did not in fact sign the said document and no contract or even document was
executed for that matter and demand strict proof thereof;
4. Defendants have no knowledge or information to form a belief as to the truth of the
averment in paragraph 5 and 6 of the complaint;
5. Defendants specifically deny under oath in the paragraph 7 and 8 the genuineness and
due execution of the alleged promissory note.
6. Defendants specifically deny the allegation in the paragraph 9 of the complaint, the
truth being that, there was no notice received by the defendants, that their signatures
are forged and that they did not in fact sign the said document and demand strict proof
thereof;

7. Defendants admit the averment in paragraph 10 insofar as the receipt of the demand
letter is concerned and not the contents thereof;
8. Defendants admit the averment in paragraph 11;
9. Defendants have no knowledge or information to form a belief as to the truth of the
averment in paragraph 12, 13 and 14 of the complaint and demand strict proof thereof;
10. Any allegation not expressly and specifically admitted herein shall be generally
denied;

AFFIRMATIVE DEFENSES
Having answered the Complaint, the Defendants, PATROCENIO ALILAM AND
ALFIANA ALILAM, assert the following enumerated Affirmative Defenses.
1. Signatures of the defendants are forged and that they did not in fact sign the alleged
documents.
2. All statements and comments made by Defendants about Plaintiff were made by the
Defendants with good motive and were fair comments;
3. The Plaintiff has failed to set forth ultimate facts due to inconsistency of the
statements as to the date of the alleged transactions executed between the parties;
4. The Plaintiff has failed to attached documents to prove that the Defendants in fact
were indebted to the Plaintiff;
5. No act or omission on the part of Defendant either caused or contributed to whatever
injury (if any) the Plaintiff may have sustained.

COUNTERCLAIM
Defendants, PATROCENIO ALILAM AND ALFIANA ALILAM allege;
1. That by virtue of this unwarranted and malicious act initiated by the Plaintiff,
Defendants were forced to engage counsel in the sum of Ten Thousand Pesos
(10,000.00)
WHEREFORE, it is respectfully prayed that the complaint be dismissed and defendant be
awarded the amount of Twenty Thousand Pesos (20,000.00)
Other just and equitable reliefs are likewise prayed for.
Tuguegarao City, Cagayan -January 24, 2015

ATTY. KIMBERLEY DELA CRUZ- MATAMMU


Carig Sur, Tuguegarao City
Attorneys Roll No. 54654
IBP No. 927307, Cagayan 1-2913
PTR No.3202399, Tuguegarao City, Cagayan, 1-21-13
MCLE Compliance No. 1110016263, 05-31-10

VERIFICATION/CERTIFICATION

We, PATROCENIO ALILAM AND ALFIANA ALILAM ,of legal age, Filipino Citizen and
residing at Sampaguita, Solana Cagayan after first having duly sworn to in accordance with law
depose and say:
1. We are the defendants in the above- entitled case
2. We have caused the preparation of the foregoing complaint
3. The contents therein are true and correct to the best of our personal knowledge
and based on authentic documents.
4. We hereby certify that we have not commenced any action or proceeding
involving the same issue in any tribunal or agency, to the best of our own
knowledge, no such action or proceeding is pending in any other tribunal or
agency and should We thereafter learn that a similar action or proceeding has been
filed or is pending in Court, we will undertake to report such fact within five (5)
days therefrom to the court wherein this Petition and this certification have been
filed.

IN WITNESS WHEREOF, We have hereunto affixed our signatures this 24th day of
January in Tuguegarao City, Cagayan Philippines.

PATROCENIO ALILAM
Affiant

ALFIANA ALILAM
Affiant

SUBSCRIBED AND SWORN to before me this 24th day of January 2015 in


Tuguegarao City, Cagayan, Philippines

ATTY. KIMBERLEY DELA CRUZ- MATAMMU


Carig Sur, Tuguegarao City
Attorneys Roll No. 54654
IBP No. 927307, Cagayan 1-2913
PTR No.3202399, Tuguegarao City, Cagayan, 1-21-13
MCLE Compliance No. 1110016263, 05-31-10

CERTIFICATE OF SERVICE

We certify that on 24th of January 2015, the original of this document was filed with the
Clerk of Court; and, a true and accurate copy of this document was served on the other party
mail, addressed to the following:
TO: ATTY. YULO VINCENT PANUNCIO, JR
National High Way, Bantug, Roxas, Isabela

PATROCENIO ALILAM

ALFIANA ALILAM
Defendants

EXPLANATION
A copy hereof is served on opposing counsel and the Regional Trial Court by registered
mail, instead of by personal service, due to the urgency of filing the same and due to lack of
messenger of the undersigned counsel for the moment.

ATTY. KIMBERLEY DELA CRUZ- MATAMMU


Counsel for Defendants