Republic of the Philippines

METROPOLITAN TRIAL COURT

National Capital Judicial Region
Branch ____, Quezon City

NAPOLEON C. GATMAITAN

Plaintiff,
-versus-

EDGARDO S. SANTOS

Defendant.

CIVIL CASE NO. _____

For:
Collection of a Sum of Money

X - - - - - - - - - - - - - - - - - - - - - - - - - - -X

ANSWER
COMES NOW the defendant EDGARDO S. SANTOS thru the undersigned
counsel, respectfully alleges:
1. That he specifically denies under oath the genuineness and due execution of
the alleged Acknowledgement of Debt (Annex A) and Loan Agreement (Annex B)
attached to the plaintiffs complaint;
2. That the said two documents were fraudulently executed by the plaintiff
NAPOLEON C. GATMAITAN, the defendant EDGARDO S. SANTOS not having
executed any such promissory note in favor of the former, thus, the said promissory note
is null and void.
WHEREFORE, it is respectfully prayed that the plaintiffs complaint be
dismissed with costs against the plaintiff. The defendant further prays for such other
relief as the Honorable Court may deem just and equitable.
Quezon City,_____________

ATTY. LOUISE MARIE S. PEREZ

Counsel for Defendant
Citibank Tower Eastwood City Bagumbayan, Quezon City
Roll No. 87432 IBP No. 863992 dated 1-5-10
MCLE Compliance No. 11-00083469

COPY FURNISHED:
Atty. Angelico Zenon M. Delos Reyes
Counsel for the Plaintiff
Phoenix Sun Business Park E. Rodriguez Jr. Ave.,
Libis, Quezon City

VERIFICATION
I, EDGARDO S. SANTOS, of legal age, Filipino and with address at # 15 Bohol
St., Barangay Horseshoe, Quezon City, having been duly sworn to in accordance with
law hereby depose and say:
1. That I am the Defendant in the above-entitled case; that I have caused the
preparation of the foregoing Answer Pleading; that all the allegations stated therein are
true and correct of my own knowledge and supported by authentic documents;
2. That I have not commenced any other action or proceeding involving the same
issues is the Supreme Court, the Court of Appeals, or any other tribunal or agency; that
to the best of my knowledge, no such action or proceeding is pending in the Supreme
Court, the Court of Appeals, or any other tribunal or agency; that there is no other action
or proceeding which is either pending or may have been terminated, and if I should
thereafter learn that a similar action or proceeding has been filed or is pending before
the Supreme Court, the Court of Appeals, or any tribunal or agency, I undertake to
report that fact within five (5) days there from to this Honorable Court.

EDGARDO S. SANTOS
Affiant

SUBSCRIBED AND SWORN to before me this ____ day of _______ at Quezon

City affiant exhibiting to me her Community Tax Certificate No. __________ issued in
___________ on ____________

NOTARY PUBLIC

Doc. No.________;
Page No.________;
Book No.________;
Series of ________;